Justia U.S. 9th Circuit Court of Appeals Opinion Summaries

Aerotec Int’l v. Honeywell Int’l

By
Aerotec is a small, independent company that provides maintenance, repair and overhaul (MRO) services for Honeywell's auxiliary power units (APUs). Aerotec filed suit alleging causes of action under sections 1 and 2 of the Sherman Antitrust Act, 15 U.S.C. 1, 2, the Robinson-Patman Act, 15 U.S.C. 13(a), and Arizona state law. Aerotec alleges that Honeywell leverages its monopoly power over the APU parts market to unfairly smother competition in the repair services market. The court concluded that Aerotec’s chain of logic and evidence is too attenuated to support liability for tying under section 1, and none of the indicia that the court would ordinarily review in an exclusive dealing claim are present in the record. The court rejected Aerotec's monopolization claims under section 2, concluding that Aerotec's refusal to deal claim fails based on its vague requested remedy that the court order Honeywell to provide parts, data, and prices like it did before 2007. Furthermore, reasonable access to the essential facility exists and Aerotec cannot establish an essential facilities claim. The court rejected Aerotec's claim that Honeywell engages in unlawful conduct by simultaneously charging a low (but above-cost) price for its repair bundles and raising the wholesale price of replacement parts. Finally, the court rejected Aerotec's claim that Honeywell engages in secondary-line price discrimination under the Robinson-Patman Act. Accordingly, the court affirmed the judgment. View "Aerotec Int'l v. Honeywell Int'l" on Justia Law