CASE COMMENTS: INTERNATIONAL POLICY – UNITED STATES – SECTION 1 OF THE SHERMAN ACT – MUTUAL STRIKE ASSISTANCE AGREEMENT – PROFIT SHARING AGREEMENT – QUICK LOOK RULE OF REASON – ANTICOMPETITIVE AGREEMENT

Mutual Strike Assistance Agreement: The US Court of Appeal for the Ninth Circuit applies a specific quick look rule of reason and invalidates a Supermarkets Chain "Mutual Strike Assistance Agreement" (State of California/Safeway)

*This article is an automatic translation of the original article, provided here for your convenience. Read the original article. United States Court of Appeals for the Ninth Circuit, August 17, 2010, State of California v. Safeway, Inc, No. 08-55671 An interesting example of the implementation of the shortened or truncated rule of reason (quick look rule of reason, as opposed to the traditional or full rule of reason; for a general presentation, see J. E. Hartley et al, The Rule of Reason, ABA Section of Antitrust Law, monograph 23, 1999). Following the American Needle decision, the framework for analyzing cartels has been refined but also made more complex (American Needle, Inc. v. National Football League et al., 560 U.S., 2010, ConcurrencesNo. 3-2010, comm. F. D.-J. and F. S.).

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Jean-Christophe Roda, Mutual Strike Assistance Agreement: The US Court of Appeal for the Ninth Circuit applies a specific quick look rule of reason and invalidates a Supermarkets Chain "Mutual Strike Assistance Agreement" (State of California/Safeway), 17 August 2010, Concurrences N° 1-2011, Art. N° 34394, pp. 226-229

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