Matsushita Electric Industrial Co. v. Zenith Radio Corp.
United States Supreme Court
475 U.S. 574 (1986)
Zenith and National Union Electric (plaintiffs) sued Matsushita and 20 other Japanese consumer-electronics manufacturers (defendants), alleging a decades-long predatory-pricing conspiracy dating to 1953, in which the defendants sold products at artificially low, loss-generating prices in the U.S. to drive out American manufacturers and monopolize the market. The district court granted the defendants summary judgment; the court of appeals reversed, finding a factfinder could infer a conspiracy from several circumstances, and the Supreme Court granted certiorari.
Whether, to survive a motion for summary judgment, a plaintiff seeking damages for a violation of section 1 of the Sherman Act must present evidence that tends to exclude the possibility that the alleged conspirators acted independently.