The U.S. Court of Appeals for the Seventh Circuit refused to apply U.S. antitrust law in a case where allegedly price-fixed component parts were sold and combined into completed products abroad before being sold to U.S. consumers. A district court decided that chocolate bar manufacturers would not have to face antitrust conspiracy charges at trial because the evidence did not support an inference that their parallel price increases were the result of collusion.
Other antitrust developments of note included the Supreme Court’s agreement to review a case interpreting the application of the state action immunity doctrine to a North Carolina dentists board, which sought to curtail services by non-dentists, and the New York Attorney General’s imposition of novel remedies in a hospital merger case.
