Aerotec Int'l v. Honeywell Int'l, No. 14-15562 (9th Cir. 2016)
Annotate this CaseAerotec is a small, independent company that provides maintenance, repair and overhaul (MRO) services for Honeywell's auxiliary power units (APUs). Aerotec filed suit alleging causes of action under sections 1 and 2 of the Sherman Antitrust Act, 15 U.S.C. 1, 2, the Robinson-Patman Act, 15 U.S.C. 13(a), and Arizona state law. Aerotec alleges that Honeywell leverages its monopoly power over the APU parts market to unfairly smother competition in the repair services market. The court concluded that Aerotec’s chain of logic and evidence is too attenuated to support liability for tying under section 1, and none of the indicia that the court would ordinarily review in an exclusive dealing claim are present in the record. The court rejected Aerotec's monopolization claims under section 2, concluding that Aerotec's refusal to deal claim fails based on its vague requested remedy that the court order Honeywell to provide parts, data, and prices like it did before 2007. Furthermore, reasonable access to the essential facility exists and Aerotec cannot establish an essential facilities claim. The court rejected Aerotec's claim that Honeywell engages in unlawful conduct by simultaneously charging a low (but above-cost) price for its repair bundles and raising the wholesale price of replacement parts. Finally, the court rejected Aerotec's claim that Honeywell engages in secondary-line price discrimination under the Robinson-Patman Act. Accordingly, the court affirmed the judgment.
Court Description: Antitrust. The panel affirmed the district court’s grant of summary judgment in favor of defendant Honeywell International, Inc., on antitrust claims brought by Aerotec International, Inc. Aerotec, a small, independent company that provides maintenance, repair, and overhaul services for Honeywell- manufactured auxiliary power units for aircraft, alleged that Honeywell leveraged its monopoly power over the auxiliary power unit parts market to unfairly smother competition in the repair services market. The panel held that Aerotec failed to establish either positive or negative tying in violation of § 1 of the Sherman Act because there was no condition linking the sale of a tying product with the sale of the tied product. Aerotec also presented insufficient evidence of exclusive dealing under Sherman Act § 1. As to monopolization claims under Sherman Act § 2, Areotec failed to establish foreclosure of competition through a refusal to deal or a denial of essential facilities. Aerotec also failed to establish liability on the basis of bundled parts and repairs. The panel affirmed the district court’s summary judgment on a price discrimination claim under the Robinson-Patman AEROTEC INT’L V. HONEYWELL INT’L 3 Act because Aerotec failed to establish actionable discrimination in price between independent servicers and Honeywell’s affiliates.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.