In re: Automotive Parts Antitrust Litigation, No. 20-1599 (6th Cir. 2021)
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A class of end-payor purchasers sued (Clayton Act, 15 U.S.C. 26; Sherman Act, 15 U.S.C. 1) manufacturers and suppliers, alleging that they conspired to fix prices of automotive anti-vibration rubber parts. The district court certified a nationwide settlement class comprising persons and entities who indirectly purchased anti-vibration rubber parts that were manufactured or sold by the defendants, excluding persons or entities who purchased parts directly or for resale.
Before the court entered final judgments approving the "indirect purchaser" settlement, Plaintiffs filed a separate suit against the same defendants, in the same court, seeking damages under the Clayton Act on behalf of a putative class of “direct purchasers” of anti-vibration rubber parts. They alleged that they purchased parts “from an entity (Firestone retail shop) of which one of the Defendants (Bridgestone) is the ultimate parent”; Firestone is not a defendant in either lawsuit. Bridgestone is a defendant in both. The court entered final judgments in the end-payor lawsuit, enjoining all settlement class members from “commencing, prosecuting, or continuing . . . any and all claims” arising out of or relating to the released claims.
Defendants moved to enjoin Plaintiffs from litigating their direct-purchaser lawsuit. The district court denied the motion, citing “Illinois Brick.” Under federal antitrust law, a private plaintiff generally must be a “direct purchaser” to have suffered injury and have standing to sue a manufacturer or supplier. In Illinois Brick, the Supreme Court recognized an exception, holding that an “indirect purchaser” might have standing if it purchased from an intermediary that was “owned or controlled” by the ultimate seller.
The Sixth Circuit reversed. Regardless of whether Illinois Brick applies to plaintiffs’ underlying claims, plaintiffs fit within the class definition under the plain meaning of the settlement agreements. Their suit is therefore barred.
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