Ward v. Apple, Inc.

Plaintiffs filed a putative class action against Apple, alleging that Apple conspired with ATTM to violate federal antitrust laws by entering into an exclusivity agreement in which ATTM would be the exclusive provider of voice and data services for Apple's iPhone. The district court dismissed plaintiffs' claims under F.R.C.P. 19 for failure to join ATTM as a defendant. As a preliminary matter, the court determined that it had jurisdiction over the appeal under 28 U.S.C. 1291 because this is an appeal from a final decision of the district court. On the merits, the court concluded that ATTM's role as an antitrust co-conspirator is not alone dispositive of whether it had interests that warrant protection under Rule 19(a)(1)(B)(i). In this case, the district court erred by failing to specify the interests ATTM claimed or to address how those interests might be impaired if the action were resolved in its absence. The court concluded that Apple has not demonstrated that ATTM has a legally protected interest in this action where Apple has not demonstrated that the risk of regulatory scrutiny gives ATTM a legally protected interest in this action; ATTM’s reputational interests in this action are not legally protected under Rule 19; and Apple has not demonstrated that ATTM currently has any substantial contract rights that may be impaired by resolution of this action. Accordingly, the court reversed and remanded. View "Ward v. Apple, Inc." on Justia Law