In Meyer v. Qualcomm, the court dismissed the claim that Qualcomm acted anticompetitively in refusing to license patents essential to a standardized technology. The S.D. of California court ruled that the plaintiff lacked antitrust standing because the chip set it purchased included a broad package of technologies, not just the patented technology involved. Although the claim would not have been barred under the indirect purchaser rule alone, the court held that the plaintiff was too remote to constitute a proper plaintiff.
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