Continental Ore Company v. Union Carbide and Carbon Corporation

Vanadium Corporation of America (VCA) and Union Carbide (Carbide) (defendants), who controlled over 90 percent of the U.S. vanadium market, allegedly conspired to eliminate Continental Ore (plaintiff) from both the U.S. and Canadian vanadium markets; Carbide's subsidiary Electro Met, which the Canadian government had authorized to allocate wartime vanadium resources, excluded Continental from the Canadian market and redirected its share to Carbide and VCA. The district court refused to hear evidence on the Canadian-market allegations, finding Electro Met's government-authorized actions outside the Sherman Act's scope, and the court of appeals affirmed.