District of Ohio Judge George Smith dismissed an antitrust case against the American Mastiff Breeders Council by a former member. The plaintiff alleged that the council violated the antitrust laws by setting capping the price that could be charged for puppies and by excluding the plaintiff from the organization. The court held that the plaintiff lacked antitrust standing to challenge the price cap because a competitor’s inability to charge more — in the court’s view — was not antitrust injury. With respect to the boycott, the court held that the plaintiff failed to allege a relevant market in which the defendant had market power. A mastiff only market, the court held, was implausible because other breeds of dogs could perform the same functions.