In Bruce Max Davis et al. v. AT&T Wireless Services, Inc. et al., California federal judge Dean D. Pregerson, tossed a putative antitrust conspiracy class action under the Sherman Act and California Cartwright Act. The complaint alleged price-fixing and unfair competition, and was filed by multimedia content owners and producers against AT&T Mobility LLC, Verizon Wireless, Sprint Spectrum LP, T-Mobile USA Inc., and TracFone Wireless Inc. The plaintiffs claimed that the carriers collectively decided to ignore recommendations to implement digital rights management measures that would have protected third-party copyrighted materials when they created the Multimedia Messaging Service (MMS). The court granted defendants’ motion to dismiss, holding that the plaintiffs lacked standing to bring antitrust claims against participants in a different market. Judge Pregerson’s March 2011 dismissal of a separate, similar case, Luvdarts LLC et al. v. AT&T Mobility LLC et al., on the grounds that the companies didn’t have the right and the ability to prevent infringement barred this case.