In In re: TFT-LCD (Flat Panel) Display Antitrust Litigation, N.D. California Judge Susan Illston denied the LCD television manufacturers’ motion to dismiss a private action filed by direct purchasers. The defendants argued that the allegations of conspiracy were too vague outside the post-2000 period covered by the defendants’ executives guilty pleas in a related criminal proceeding. Pointing to “numerous illicit conspiratorial communications between and amoung the defendants,” the court found the allegations more than sufficient for the period from 1996 to 2001. The court did dismiss indirect purchaser claims, which are generally not cognizable under federal law. Some states permit indirect purchase claims, and the plaintiffs had sought to rely on the antitrust laws of various states. The court held that Virginia, Montana, and Puerto Rico antitrust laws did not extend to indirect purchasers.