Anderson News, L.L.C. v. American Media, Inc., No. 10-4591 (2d Cir. 2012)Annotate this Case
This action involved the single-copy magazine industry, i.e., the business of selling magazines for purchase by consumers at retail outlets. Anderson appealed (1) from a judgment of the district court dismissing their complaint alleging that defendants, who were suppliers and business competitors, conspired to drive Anderson out of business in violation of section 1 of the Sherman Antitrust Act, 15 U.S.C. 1, and New York law, and (2) from an order denying Anderson's motion for reconsideration and for leave to file a proposed amended complaint. The court concluded that even if the original complaint did not meet the Twombly/Igbal standard, Anderson's proposed amended complaint, which contained additional factual allegations, met that standard and should have been allowed. Accordingly, the court vacated the judgment of dismissal and remanded for further proceedings.