In Metropolitan Regional Information Systems Inc. v. American Home Realty Network Inc. et al., District of Maryland Alexander Williams Jr. dismissed antitrust claims arising in a copyright infringement case. The court held that the defendant real estate referral service did not plausibly allege that the plaintiff conspired to file sham copyright infringement suits intended to restrain competition.
The court explained that the counter-claimant failed “to plead the time, place and contours of any anti-competitive agreement.” An allegation that copyright owners agreed to enforce their intellectual property rights, the court explained, is not sufficient to allege a conspiracy harming competition.
The court provided the defendant with an opportunity to amend its antitrust claim to satisfy the pleading problems.