The Nineth Circuit recently upheld the dismissal of a price fixing case against computer memory chip manufacturers that had been filed by Centerprise, a British computer manufacturer. The court held that the Foreign Trade Antitrust Improvements Act requires a foreign consumer to show that its injury flowed directly from anticompetitive effects of the defendants’ conduct in the United States. Centerprise had argued that the defendants’ worldwide price fixing conspiracy could not have been effective unless the U.S. market was included. The court found this allegation insufficient to establish the requisite direct injury.