In Sky Angel U.S. LLC v. National Cable Satellite Corp. d/b/a C-SPAN, District of Columbia Judge Rudolph Contreras dismissed Sky Angel’s antitrust suit against National Cable Satellite Corp. (C-SPAN). In its suit, Sky Angel, a Christian Internet television provider, claimed that C-SPAN violated §1 of the Sherman Act by pulling its programming from Sky Angel’s services. Sky Angel also accused C-SPAN of violating §2 by monopolizing the distribution of real-time, multichannel video programming.
In dismissing Sky Angel’s claims, the court held that the presence of representatives from cable TV competitors on C-SPAN’s board of directors did not render the board’s decisions horizontal conspiracies. The court further held that Sky Angel’s complaint did not adequately define a relevant market or allege that C-SPAN holds monopoly power.