De Facto Exclusive Dealing: What a Difference a Day Makes* In Competition Law360, September 4, 2013, we reported on the dismissal of a complaint which alleged, inter alia, exclusive-dealing claims in a market described as the management and distribution of “photographs in rich media content for hotels”. Plaintiff Pro Search (“Pro Search”) alleged that defendant VFML Leonardo, Inc. (VFML”) violated Sections 1 and 2 of the Sherman Act by entering into exclusive-dealing agreements which allegedly excluded Pro Search from participation in the defined relevant market. Pro Search alleged that VFML had approximately 80% of the relevant market. Nevertheless, the U.S. District Court for the Central District of California, sitting in Santa Ana, dismissed the First Amended Complaint (“FAC”) on the
The US District Court of California dismisses tying claim related to the market for distribution of hotel content since the tying product and the tied product were not separate (Pro Search Plus / VFML Leonardo)
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