SD3, LLC v. Black & Decker, No. 14-1746 (4th Cir. 2015)Annotate this Case
SawStop filed suit against two dozen saw manufacturers and affiliated entities under section 1 of the Sherman Antitrust Act, 15 U.S.C. 1, contending that several major table-saw manufacturers conspired to boycott SawStop’s safety technology and corrupt a private safety-standard-setting process, all with the aim of keeping that technology off the market. The district court dismissed SawStop's amended complaint. The court concluded that SawStop's complaint does not plausibly allege any conspiracy to manipulate safety standards; the complaint also fails to allege any facts at all against several corporate parents and affiliates; and therefore, the court affirmed the district court's dismissal as to these claims. However, the court concluded that SawStop has alleged enough to suggest a plausible agreement to engage in a group boycott where the complaint offers enough to survive defendants’ motion to dismiss. Accordingly, the court vacated the district court's dismissal as to this claim and remanded for further proceedings.
The court issued a subsequent related opinion or order on October 29, 2015.