In Rockwell Automation Inc v. AU Optronics Corporation et al., Northern District of California Judge Susan Illston rejected LG Display Co. Ltd.’s argument that Rockwell Automation Inc.’s state price-fixing claims would lead to duplicative recovery in the multidistrict litigation over liquid crystal display panels. LG brought counterclaims and affirmative defenses against Rockwell’s Wisconsin state law claims arguing that the Wisconsin statute barred double recovery since LG had already paid to settle and continued to face claims from buyers both “above and below Rockwell on the distribution chain.” Judge Illston rejected LG’s argument and held that based on her earlier decisions in this MDL, duplicative recovery is often a “necessary consequence” from state indirect purchaser damages claims in cases alleging a nationwide price-fixing plot when federal claims from direct buyers are also involved.