Gatt Communications, Inc. v. PMC Associates, L.L.C., No. 11-1111 (2d Cir. 2013)
Annotate this CaseThis case involved an alleged bid-rigging scheme that sought to defraud various New York State and City government agencies in connection with the purchase by those agencies of a particular brand of mobile radio. Gatt, an admitted past participant in the purported scheme, sought to recover damages from alleged co-conspirators for losses arising from the termination of Gatt's at-will distribution contract for those radios. Gatt raised federal and state antitrust claims arising under the Sherman Act, 15 U.S.C. 1; the Donnelly Act, N.Y. Gen. Bus. Law 340; and New York common law. The court concluded that Gatt lacked antitrust standing to pursue its antitrust claims and that its common law claims were properly dismissed as a matter of law. Therefore, the court affirmed the district court's dismissal of Gatt's complaint.
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