The plaintiffs in In re: ATM Fee Antitrust Litigation have responded to the Northern District of California court’s grant of summary judgment to the defendants’ on their plaintiffs’ per se theory by amending the complaint to allege a rule of reason violation. The complaint alleges that the banks participating in the Star ATM network have jointly set the interchange fee paid by the bank issuing the ATM card to the ATM owner that processes a transaction. This fee is sometimes passed on to the cardholder, allegedly in some cases with a markup. Previous challenges to credit card interchange fee setting have been decided under the Rule of Reason because of the pro-competitive aspects of the joint venture forming the card network.