In Jordan Katz et al. v. Fidelity National Title Insurance et al., the Sixth Circuit affirmed the dismissal of a consolidated class action accusing 22 title insurers of conspiring with an Ohio rating bureau to fix prices. In their suit, plaintiffs claimed that the title insurers violated the Sherman Act and Ohio’s Valentine Act when they conspired with the Ohio Title Insurance Rating Bureau to fix prices for title insurance. Plaintiffs further claimed that the inflated rates the insurers set hid unlawful kickbacks and other charges unrelated to title insurance. In April 2010, Ohio District Judge dismissed plaintiffs’ claims, finding that the McCarran-Ferguson Act and Ohio state law barred the claims completely and that the filed-rated doctrine foreclosed damages and injunctive relief. The Sixth Circuit affirmed the dismissal, holding that the plaintiffs’ federal claims were barred, since the McCarran-Ferguson Act bars federal antitrust actions related to an insurance business where a state regulates the business, and Ohio regulates title insurance. The court declined to address the filed-rate doctrine issue because the McCarran-Ferguson Act and Title XXXIX of the Ohio Revised Code are complete bars to plaintiffs’ federal and state antitrust claims, so there was no need to consider the filed-rate doctrine issue.