Eastman Kodak, Co. v. Henry Bath LLC, No. 16-4230 (2d Cir. 2019)Annotate this Case
In three consolidated actions, plaintiffs challenged the district court's grant of summary judgment for defendants and dismissal of their complaints alleging violations of Section 1 of the Sherman Act through a conspiracy to inflate prices in the primary aluminum market.
The Second Circuit held that the district court erred by determining that plaintiffs failed to establish antitrust standing under In re Aluminum Warehousing Antitrust Litig. (Aluminum III), 833 F.3d 151 (2d Cir. 2016). The court held that the circumstances of these plaintiffs differed materially from those involved in Aluminum III, and the rationale of Aluminum III did not apply to their complaints. In this case, the evidence adduced by plaintiffs supported their contention that defendants' conspiratorial acts inflated a component of the price of primary aluminum.