In Eatoni Ergonomics Inc. v. Research in Motion Corp. et al, the Second Circuit affirmed the trial court’s decision that BlackBerry maker Research In Motion Ltd. (RIM) did not violate the antitrust laws when it backed out of a joint product development deal with Eastoni Ergonomics.
In 2004, Eatoni accused RIM’s BlackBerry devices of infringing its intellectual property on the reduced QWERTY keyboard. The parties settled that dispute with RIM agreeing to (1) invest $2 million in Eatoni and (2) collaborate to improve predictive text cellphone keyboards. Eatoni agreed to license its patent. When RIM decided to end the collaboration, the parties took the dispute to arbitration and the decision favored RIM. Eatoni then filed this antitrust action alleging that RIM had monopolized the market for the reduced QWERTY devices.
The court held that the law does not impose a duty requiring RIM to work with the plaintiff, and the settlement required only bargaining in good faith, a standard that RIM met. Further, the court held that allegations of patent infringement do not constitute an antitrust claim.