In In re: TFT-LCD (Flat Panel) Antitrust Litigation, Northern District of California Judge Susan Illston denied a motion to dismiss price-fixing claims related to the sale of cellphones and digital cameras brought by several retailers against liquid crystal display manufacturers. This case is part of a consolidated multidistrict class action suit, where direct purchasers of LCD panels and retailers accused LG Display Co. Ltd and other LCD manufacturers of illegally fixing prices in the TFT-LCD market during a series of meetings.
Defendants moved to dismiss the price-fixing claims, arguing that the retailers, such as Best Buy Co. Inc., Target Corp., Kmart Corp., and Sears Roebuck & Co., lacked standing to bring antitrust claims over the sale of the electronics. Defendants argued that the market for LCD components is distinct from the market for cellphones and digital cameras, and the LCD components make up only a fraction of the finished electronic devices. Any potential damages would thus be speculative. The court denied defendants’ motion, holding that the market for LCD components and electronics that use them are “inextricably linked” because the LCD components have no independent utility. The retailers’ alleged damages therefore flowed directly from the fixed price on the LCD displays that are incorporated into cellphones and digital cameras.