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Per Se Analysis

Cases on the boundary of per se illegality: overlap of potentially illegal agreements with otherwise legitimate business activities'

  • Topco (grocery brand)
  • BRG (non-compete in licensing contract)
  • NSPE / IN Dentists / CDA (professional associations)
  • NCAA (competitive league)
  • Dagher (joint venture)

Considerations on the boundary of per se illegality:

  • Is the restriction too broad relative to any lawful purpose? Topco, NSPE
  • Would prohibition prevent equivalent market organization by low-cost, substitute means?
    • Topco: probably not, co-op can still operate without geographic restrictions and stores can achieve geographic spacing without cooperation
    • BMI: certainly in the short term, blanket license may be unavailable if per se illegal
  • Is there direct or indirect evidence of anticompetitive harm or market power?
    • NSPE and BRG: evidence of price increases
    • Topco: evidence suggests that competitive harm was unlikely

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