MacDermid Printing Sols. LLC v. Cortron Corp.

Cortron appealed the district court's award of damages pursuant to a jury verdict of MacDermid on its claims for violations of federal and Connecticut antitrust laws, breach of contract, misappropriation of trade secrets, spoliation, and violations of Connecticut statutes prohibiting computer crimes and unfair trade practices. At issue are the requirements for proving an adverse effect on competition for purposes of section 1 of the Sherman Act, 15 U.S.C. 1, in cases where the plaintiff has not proved that the allegedly anticompetitive behavior led to higher prices, reduced output, or lower quality in the market. The court held that a plaintiff may not prevail under the “rule of reason” merely by proving that (1) the defendant exercised “market power,” and (2) the challenged behavior may have misled consumers to believe that certain products were no longer available, without showing that consumers actually experienced reduced access to those products. In this case, the court agreed with Cortron that the district court erred in denying Cortron judgment as a matter of law with respect to MacDermid’s antitrust claims because MacDermid failed to present evidence that Cortron’s conduct harmed competition. Accordingly, the court reversed as to this claim. The court otherwise affirmed the judgment and remanded for recalculation of damages. View "MacDermid Printing Sols. LLC v. Cortron Corp." on Justia Law