In Oliver et al. v. SD-3C LLC et al., Northern District of California Judge Jeffery S. White dismissed a putative consumer class action accusing Panasonic Corp., Toshiba Corp., and SanDisk Corp. of trying to corner the SD memory card market by requiring competitors to enter restrictive patent-licensing agreements that allegedly inflated prices. Defendants filed a motion to dismiss on the ground that the antitrust claims violate the statute of limitations. In opposing defendants’ motion, plaintiffs argued that the licensing deal resulted in inflated prices within the typical four-year statute of limitations. The court disagreed, holding that the alleged transgressions stem from a 2003 licensing agreement. As such, on the continuing violation theory alleged in this case, the statute of limitations runs from the time of the last overt act made by the defendant, not from the last purchase made by a potential plaintiff. The court did not grant indirect purchasers leave to amend their complaint because the court had already dismissed a similar related suit brought against SD-3C and Panasonic by Samsung Electronics Co. Ltd., for being time-barred.