Northern District of California Judge Charles Breyer has granted summary judgment to several banks charged with fixing the interchange fees on ATM transactions. The court held that the plaintiffs, bank customers, were indirect payers of the interchange fees, which are imposed directly on the banks. Although the customers likely bore the brunt of those fees thorough foreign ATM fees, they did allege that the banks conspired to fix the foreign ATM fees that the customers paid directly. Under the Illinois Brick rule, the court held that the plaintiffs could not recover damages and granted summary judgment.