In Rheumatology Diagnostics Laboratory Inc. et al. v. Aetna Inc., et al, Northern District of California Judge Jon Tigar dismissed medical testing labs’ antitrust suit alleging that Quest Diagnostics improperly offered insurers incentives so that they would refuse to deal with its competitors. The suit accused Quest of offering predatory discounts to health insurance companies for lab work in return for the insurers’ refusal to negotiate with Quest’s rivals or include them within their networks.
In dismissing plaintiffs’ suit, Judge Tigar held that the complaint had not demonstrated how the challenged agreements affected labs that were not parties and thus failed to show substantial foreclosure of the market. He also found no evidence of a horizontal agreement among insurers or that Quest influenced Blue Cross & Blue Shield’s trademark licensing decisions that allegedly drove individual states’ Blue Plans to enter nearly exclusive arrangements with Quest.