California Court of Appeal

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Aerotec Int'l, Inc. v. Honeywell Int'l, Inc., 14-15562

In an antitrust case brought by a small company that provides maintenance, repair, and overhaul services for defendant-manufactured auxiliary power units for aircraft, alleging that defendant leveraged its monopoly power over the auxiliary power unit parts market to unfairly smother competition in the repair services market, the District Court's judgment in favor of defendant is affirmed where: 1) plaintiff failed to establish either positive or negative tying in violation of section 1 of the Sherman Act because there was no condition linking the sale of a tying product with the sale of the tied product, and also presented insufficient evidence of exclusive dealing under Sherman Act section 1; 2) as to monopolization claims under Sherman Act section 2, plaintiff failed to establish foreclosure of competition through a refusal to deal or a denial of essential facilities, and also failed to establish liability on the basis of bundled parts and repairs; and 3) as to the price discrimination claim under the Robinson-Patman Act, plaintiff failed to establish actionable discrimination in price between independent servicers and defendant's affiliates.

Appellate Information

  • Decided
  • Published 2016/09/09

Judges

  • McKEOWN

Court

  • California Court of Appeal

Counsel