United States v. Continental Can Co.
United States Supreme Court
378 U.S. 441 (1964)
Continental Can Company (defendant), the second-largest metal-container manufacturer, acquired Hazel-Atlas Glass Company, the third-largest glass-container manufacturer. The United States (plaintiff) sued to unwind the merger under Section 7 of the Clayton Act, but the district court defined the relevant product market narrowly -- treating metal and glass containers as largely separate markets except for beer containers -- and dismissed the case for failure to show significant anticompetitive effects in either market alone. The government appealed the market definition.
Whether metal and glass containers must be perfectly interchangeable to be treated as part of the same product market for antitrust purposes, given evidence of ongoing competition between the two.