In In Re: New Jersey Title Insurance Litigation, New Jersey District Court Judge Garrett E. Brown Jr. has tossed an antitrust action that accused more than a dozen major title insurers of conspiring with a New Jersey rating bureau to fix prices. In urging dismissal the defendants maintained that the plaintiffs’ claims were barred by the filed rate doctrine, under which rates submitted to a regulatory agency, including title insurance rates, are considered per se reasonable even assuming anti-competitive behavior. However, plaintiffs argued that the doctrine should not forbid their antitrust claims because the Department of Banking and Insurance did not conduct a meaningful review of the defendants’ proposed rates. In dismissing the complaint with leave to amend, Judge Brown found plaintiffs’ argument lacking, because the “application of the filed rate doctrine does not depend upon meaningful agency review of filed rates, and there is no fraud exception to the filed rate doctrine.”