Antitrust and Unfair Competition Law Section
News from the Section
Webinar: Practical Strategies for Working Efficiently and Effectively with Economic Experts
Thursday, July 30, 2015, 12 noon - 1 p.m.
This program offers 1 hour participatory MCLE credit. You must register in advance in order to participate.
Join us for a practically oriented discussion of how to find the right economic expert, work efficiently with your economic expert's team at various stages of litigation, and communicate effectively while still preserving privilege. We will discuss general strategic considerations, applicable legal standards, and tips for challenges that often arise when working with economic experts in federal civil litigation. Topics to be covered include finding and retaining an economic expert, what communications with experts are privileged, the discoverability of various materials associated with preparing expert reports, protective order and joint defense group considerations, preparing for expert depositions, and the role of economic experts in the very early stages of litigation.
- Andrew Abere, The Brattle Group
- Rachel Brass
- Brendan Glackin, Lieff Cabraser Heimann & Bernstein
Moderator: Anna Fabish, O'Melveny & Myers LLP
2015 Golden State Institute
SAVE THE DATE: The Golden State Antitrust Institute, the West Coast’s premier antitrust and unfair competition gathering is set for October 29, 2015 at the Julia Morgan Ballroom in downtown San Francisco.
At the luncheon there will be a Q&A with California Supreme Court Chief Justice Tani Cantil-Sakauye.
The Honorable Susan Illston is confirmed to moderate the panel GSI 25th Anniversary Retrospective and Prospective Views on CA Antitrust and Unfair Competition Law. A panel of preeminent plaintiffs' lawyers and defense counsel will discuss the major changes in California antitrust law and the UCL over the last 25 years and what the panelists prognosticate for the future.
A distinguished group of federal judges will also discuss trial proceedings in antitrust and complex commercial litigation. The focus will be their “real world” experiences and practice pointers.
- Hon. William Orrick III
United States District Court Judge for the Northern District of California -- San Francisco, CA
- Hon. Christina Snyder
United States District Judge for the Central District of California -- Los Angeles, CA
- Hon. Jon S. Tigar
United States District Judge for the Northern District of California -- San Francisco, CA
At the awards dinner, we will honor as our Antitrust Lawyer of the Year Craig C. Corbitt, who has been centrally involved in dozens of the most significant civil antitrust cases in the United States during his 35 year career.
For more information, see Golden State Institute.
Certification of End-Payor Classes Denied in Cephalon Antitrust Suit
Judge Mitchell Goldberg, in a 72-page opinion on June 10, 2015, denied the request by health plans and consumers for class certification in antitrust litigation involving Cephalon's sleep-disorder drug Provigil. Vista Healthplan, Inc., et al. v. Cephalon, Inc., et al., No. 2:06-cv-1833 (E.D. Penn.). The decision was issued two weeks following a record $1.2 billion settlement between the Federal Trade Commission and Cephalon over pay-for-delay claims.
The plaintiffs sued Cephalon and four generic drug makers for entering into reverse-payment settlements they claimed excluded and delayed generic competition. Slip op. at 1-2. The plaintiffs sought certification of two classes: (1) a class of end payors based on claims under antitrust and consumer protection laws of 23 states and the District of Columbia, and (2) an unjust enrichment class based on claims under the laws of 25 states and the District of Columbia. Id. at 2. The plaintiffs' expert opined that, but-for the settlement agreements, the generic makers would have launched their generic version of Provigil sooner, which would have brought significant savings to end payors. He estimated the aggregate amount of overcharges to be $2.449 billion. He also examined the defendants' profits gained from the alleged anticompetitive conduct and opined that the aggregate amount owed to the unjust enrichment class was $2.507 billion. Id. at 39.
The defendants presented competing expert testimony that significant variations in the pharmaceutical and insurance industries prevented the plaintiffs from being able to identify class members or prove antitrust impact and damages without individualized inquiry. The defense expert also identified several categories of potentially uninjured persons who might otherwise fall within the proposed class definition: brand loyalists, consumers with the same copay for branded and generic drugs, consumers who had no out-of-pocket expenses, and consumers whose insurers would place the generic version on a "non-preferred" tier.
On the issue of ascertainability, the Court examined recent Third Circuit law, which requires a two-fold inquiry: (1) the class is "defined with reference to objective criteria; and (2) there is "a reliable and administratively feasible mechanism for determining whether putative class members fall within the class definition." Id. at 10 (quoting Byrd v. Aaron's Inc., 784 F.3d 154, 163 (3d Cir. 2015)). The Court found that plaintiffs had failed to present evidence of a reliable methodology for identifying class members. Under Third Circuit precedent, it is insufficient to rely solely on a potential class member's "say so" that they belong within the class through affidavits or declarations. Id. at 11, 20 (rejecting plaintiffs' reliance on In re Nexium Antitrust Litig., 777 F.3d 9 (1st Cir. 2015)). Plaintiffs must, "at the time of class certification, present a methodology to identify class members, and prove by a preponderance of the evidence that such methodology will be effective and will not require extensive individualized inquiry and mini-trials." Id. at 19 (emphasis in original). The plaintiffs also failed to establish any administratively feasible methodology for identifying class members. Id. at 21-24. The Court distinguished the rigorous analysis required by the Third Circuit for establishing ascertainability from claims administration:
"My concerns about ascertainability focus on whether Plaintiffs can reliably identify class members at the outset. By contrast, the fund administration process would occur at the conclusion of litigation, and simply verify that any particular consumer or TPP is indeed one of the previously-identified members of the class."
Id. at 23.
On the issue of predominance in plaintiffs' antitrust claims, the Court held that the plaintiffs had not sufficiently proven that they were able to demonstrate classwide antitrust impact due to various groups of uninjured persons that remained within the class and because identifying and removing these uninjured class members would require extensive individualized inquiry. Id. at 30-38. The Court found that the prevalence of uninjured class members was more than de minimis and that plaintiffs' proposed exclusions did not resolve the predominance issue in absence of a methodology that would identify and remove those persons on a classwide basis. Id. at 34, 37.
With respect to damages, the Court held that the plaintiffs had demonstrated predominance through their expert's yardstick methodology, which took individual variations among class members into consideration. Id. at 38-45. Individual variations in damages calculations, the Court held, did not defeat predominance. Id. at 42.
The Court further held that common questions of law did not predominate as to the plaintiffs' consumer protection and unjust enrichment claims. The Court conducted choice-of-law analysis and concluded that the laws of the purchaser states govern the proposed class' consumer protection and unjust enrichment claims. Id. at 56, 69. The Court ruled that plaintiffs failed to offer a feasible solution to address variations among state laws. Id. at 60, 70.
Zelle Hofmann Voelbel & Mason LLP
District Court Refuses to Dismiss Google Wallet Data Privacy Action
In Svenson v. Google, Inc., N.D. Cal., Case No. 13-cv-04080 (N.D. Cal. Apr. 1, 2015), the Hon. Beth Labson Freeman denied a motion to dismiss a privacy class action against Google, Inc. and Google Payment Corporation (collectively, "Google") involving Google's electronic payment service, Google Wallet. The Court held that plaintiff had alleged sufficient facts to show that Google may have breached its contractual obligations and California's Unfair Competition Law ("UCL"). The Court dismissed two other claims alleging that Google had violated provisions of the Stored Communications Act ("SCA") in disclosing Google Wallet users' personal information to third parties.
Google Wallet is an electronic payment processing service application, which is the exclusive method used by customers to purchase Apps from the Google Play Store. Plaintiff alleged that prior to the filing of her lawsuit, Google's "blanket practice" was to ignore its privacy policies and share Google Wallet user's personal information with third-party mobile application ("App") vendors whenever the user purchased the App from the Google Play Store. Plaintiff alleged that sharing of such personal information, including names, addresses, zip codes, phone numbers, email addresses, and purchase authorization, was not necessary to purchase Apps and was not otherwise authorized by the Google Wallet terms of service.
Google first argued that Plaintiff had not established Article III standing to bring her state law claims for breach of contract, breach of the implied covenant, and unfair competition. The Court disagreed and held that Plaintiff has alleged facts sufficient to state these state claims, meaning that she has alleged that she suffered damages ("injury in fact") resulting from Google's breach of contract, breach of the implied covenant, and unfair competition "fairly traceable to the challenged conduct.
In its analysis of the damages element of Plaintiff's breach of contract claim, the Court considered two theories: benefit of the bargain and diminution of value of personal information. Under the first theory, Plaintiff alleged that she did not receive the contracted-for privacy protections when the services provided by Google--which obtained access to and disclosed her personal information and also retained a percentage of the App's purchase price as a fee for payment processing--were worth less than the services Plaintiff agreed to accept. The Court found these allegations were sufficient.
As to the second theory, Plaintiff alleged that Google's practice of sharing users' personal information diminished the sales value of that personal information. Plaintiff highlighted that there is a demand for personal information and, as a result of Google's conduct, Google Wallet users "have been deprived of their ability to sell their own personal data on the market." Citing to In re Facebook Privacy Litig., 572 Fed. Appx. 494 (9th Cir. 2014), the Court disagreed with Google's argument that Plaintiff was required to plead factual specificity as to how Google's use of the information deprived Plaintiff of the information's economic value. In Facebook Privacy Litig., the Ninth Circuit held that allegations that information disclosed by Facebook could be used to obtain personal information about plaintiffs, and that they were harmed by both the dissemination of such information and by losing the sales value of that information, were sufficient to establish an "injury in fact." Judge Freeman pointed out that the Ninth Circuit's holding in Facebook Privacy Litig. does not require factual specificity as to how the defendant's use of information deprived plaintiff of the information's economic value. Here, the Court held, Plaintiff's factual allegations of diminution in value of her personal information were sufficient to show a basis for contract damages for pleading purposes.
With respect to Plaintiff's UCL claim, Google argued that the thrust of plaintiff's UCL claim was Google's misrepresentation of its practice with respect to disclosure of user information and that Plaintiff must allege reliance upon these misrepresentations. The Court disagreed, holding that Plaintiff stated a claim by alleging Google violated its own privacy policies in violation of Cal. Bus. & Prof. Code § 22576 (which prohibits a commercial web site or online service operator from failing to comply with its own privacy policies), and Google's practice of making blanket disclosure of user information -- which by its very nature, frustrated the contracted-for privacy protections.
The Court dismissed Plaintiff's causes of action under the SCA, holding that the personal information shared by Google with third party App vendors was not the sort of "contents of a communication" protected by the SCA, but rather "a record or other information" that is not subject to the SCA. The Court analyzed the Ninth Circuit's decision in Zynga v. Privacy Litig., 750 F.3d 1098 (9th Cir. 2014), which held Facebook ID and the addresses of the Facebook webpage a user was viewing when the user clicked the link were not "contents of a communication" because such information was not the "substance, purport, or meaning of a communication." Judge Freeman ruled that Zynga should not be read narrowly to mean that only automatically generated data may constitute record information not subject to the SCA's protections. Rather, the Court concluded, Zynga holds that "record information" includes such information as a user's name, email address, account name, mailing address, and the like. The Court then went on to hold that Plaintiff's personal information in this instance was no more than "record information," and thus not subject to protection under the SCA.
Pritzker Levine LLP
Supreme Court Denies Certiorari Petitions in Motorola and Hui Hsuing
On June 15, 2015, the United States Supreme Court denied petitions for certiorari in Motorola Mobility LLC v. AU Optronics, 775 F.3d 816 (7th Cir. 2015) and Hsiung v. United States, 778 F.3d 738 (9th Cir. 2015). Both of these cases involved application of the Foreign Trade Antitrust Improvements Act to international cartels, and many believed that one or both of these cases would be reviewed by the Court. Prior ebriefs discussing these cases appear in reprint at the end of this article.
Motorola Mobility and Hsiung both involved the TFT-LCD price fixing conspiracy, and the courts of appeals reached conclusions about the impact of the FTAIA that some considered inconsistent. In Hsiung, criminal price fixing convictions were affirmed over FTAIA objections, while the Motorola Mobility court held the FTAIA to be a bar to the maintenance of the civil damages claims in issue. A closer look reveals the absence of any cert. worthy conflict between the two decisions, notwithstanding the ongoing differences among the courts of appeals on the proper interpretation of the FTAIA.
The claims in issue in Motorola Mobility were based on foreign purchases of price-fixed TFT-LCD panels by foreign Motorola subsidiaries. The subsidiaries assigned their claims to Motorola, which filed suit in the Northern District of Illinois.
The Seventh Circuit, in Motorola Mobility, held that the FTAIA "import commerce exclusion" did not apply (the sales of TFT-LCD panels to the subsidiaries took place overseas, and Motorola, not the defendants, imported the finished products in which the panels were incorporated), requiring that the court consider whether the foreign price fixing conduct had a "direct, substantial, and reasonably foreseeable effect" on domestic U.S. commerce that "[gave] rise to" the claims asserted by Motorola. The Seventh Circuit found no effect that gave rise to the claims assigned by the foreign subsidiaries to their U.S. parent. The harm that gave rise to the claims occurred overseas when the subsidiaries purchased the price-fixed panels.
The Ninth Circuit, in Hsuing, also considered both the import commerce exclusion and the effects exception. The court held the import commerce exclusion satisfied on the basis of its determination that the conspirators made direct import sales of price-fixed panels. That made consideration of the effects exception unnecessary, but the court nonetheless evaluated the evidence presented at trial and, as explained in the discussion that appears below, found the evidence sufficient to support a finding that the foreign conduct in issue had a direct, substantial, and reasonably foreseeable effect on domestic U.S. commerce. The Ninth Circuit noted two areas of actual or potential disagreement among the courts of appeals. With evidence of imports by conspirators, see 778 F.3d at 776, the Ninth Circuit found it unnecessary to consider the ultimate scope of the import commerce exclusion. The court did not take a position on the import commerce approach adopted by the Third Circuit in Animal Science Products, Inc. v. China Minmetals Corp., 654 F.3d 462, 470 (3d Cir. 2011) ("Functioning as a physical importer may satisfy the import trade or commerce exception, but it is not a necessary prerequisite. Rather, the relevant inquiry is whether the defendants' alleged anticompetitive behavior 'was directed at an import market.'") (quoting Turicentro, S.A. v. Am. Airlines Inc., 303 F.3d 293, 303 (3d Cir. 2002)). See 778 F.3d at 755 n.8.
The Ninth Circuit also acknowledged that the test applied under Ninth Circuit law to determine whether an effect is "direct," whether the effect "follows as an immediate consequence of the defendant's activity," is different from the "reasonably proximate causal nexus" test applied by the Second and Seventh Circuits. The court found reconsideration of the "direct" test to be beyond the power of the Hsiung panel and unnecessary because the Ninth Circuit test the court found satisfied by the Hsiung trial evidence was more favorable to the defendants than the "reasonably proximate causal nexus" test.
Neither case presented an occasion for consideration of how the import commerce exclusion might apply when the conspirators do not import price-fixed goods. The Seventh Circuit's conclusion that there was no domestic effect that "[gave] rise to" the claims asserted by Motorola, and the Ninth Circuit's determination that the effects exception was satisfied under either test, made the difference between the Ninth Circuit test and the Second/Seventh Circuit test unimportant to the outcome of either case. There was no need for Supreme Court intervention on either issue in these cases. FTAIA issues continue to be hotly contested in numerous cases, however, and Supreme Court attention to the conflicting positions adopted by the courts of appeals is needed.
Robert E. Freitas
Freitas Angell & Weinberg LLP
Reprint from the January 2015 EBrief: Seventh Circuit Bars Motorola's Antitrust Claims Based on FTAIA
In Motorola Mobility LLC v. AU Optronics Corp., 2014 U.S. App. LEXIS 22408 (7th Cir. November 26, 2014), the Seventh Circuit held that the Foreign Trade Antitrust Improvements Act ("FTAIA"), 15 U.S.C. §6a, barred almost all claims made by Motorola arising from the long-running conspiracy to fix the prices of liquid-crystal display ("LCD") panels because the conspiratorial conduct, and Motorola's purchases, largely took place outside the United States. The court held that purchases of price fixed components by Motorola's foreign subsidiaries that were incorporated into products sold and shipped to Motorola in the United States did not give rise to claims under the Sherman Act. The court further held that its decision would not restrict the ability of the United States to pursue criminal charges against foreign defendants whose price-fixed components are sold in the United States.
The court recited its view of the requirements of the FTAIA which permit foreign conduct to give rise to a claim under the Sherman Act. "First, there must be a direct, substantial and reasonably foreseeable effect on U.S. domestic commerce - the domestic American economy, in other words - and the effect must give rise to a federal antitrust claim. The first requirement, if proved, establishes that there is an antitrust violation; the second determines who may bring a suit based on it." (emphasis in original).
The court held that the "import" commerce exception to the FTAIA did not apply because it was "Motorola, rather than the defendants, that imported these panels into the United States." The court further held that the 57 percent of panels incorporated into phones sold outside the United States could not give rise to a claim under the Sherman Act.
As to the 42 percent of panels that did enter the United States, the court held that Motorola's claims were barred because the effect of the anticompetitive conduct on domestic United States commerce did not give rise to an antitrust cause of action because the "cartel-engendered price increase in the components and in the price of cellphones that incorporated them occurred entirely in foreign commerce." The court concluded that the immediate victims of the price-fixing were Motorola's foreign subsidiaries.
The decision appeared to turn in part on the court's reaction to Motorola's arguments that it and its subsidiaries are "one" for the purpose of its antitrust claims, although "for tax purposes its subsidiaries are distinct entities paying foreign rather than U.S. taxes." As the court said:
Distinct in uno, distinct in omnibus. Having submitted to foreign law, the subsidiaries must seek relief for restraints of trade under the law either of the countries in which they are incorporated or do business or the countries in which their victimizers are incorporated or do business. The parent has no right to seek relief on their behalf in the United States.
The court further noted that Motorola's efforts to avoid the consequences of the separateness of its foreign subsidiaries conflicted with the Supreme Court's decision in Illinois Brick Co. v. Illinois, 431 U.S. 720 (1977) in that Motorola was an indirect, and not a direct purchaser. Finally the Seventh Circuit emphasized that comity considerations mandated a narrow interpretation of the geographic scope of the United States antitrust laws.
Cotchett, Pitre & McCarthy, LLP
Reprint from the February 2015 EBrief: Ninth Circuit Amends AUO Decision in TFT-LCD Cartel Case, Finds "Domestic Effects" Test Satisfied
On January 30, 2015, the United States Court of Appeals for the Ninth Circuit issued an Amended Order in United States of America v. Hui Hsuing, case no. 12-10492. The January 30, 2015 order (1) amended the Ninth Circuit's opinion in United States of America v. Hui Hsuing, 758 F.3d 1074 (9th Cir. 2014), filed on July 10, 2014; (2) denied a petition for panel rehearing; and (3) denied a petition for rehearing en banc. The Hui Hsuing case is commonly referred to as "AUO", in reference to one of the primary corporate defendants.
In the Amended Order, the Ninth Circuit explicitly ruled on the "domestic effects" test of the Foreign Trade Antitrust Improvements Act ("FTAIA"), 15 U.S.C. § 6a and ruled that the domestic effects requirement of the FTAIA had been satisfied.
The case arose from the long-running cartel to fix the prices of TFT-LCD panels. The appellants were convicted of violating the Sherman Act. The cartel involved a conspiracy by Korean and Taiwanese companies which included five years of secret meetings in Taiwan, sales of TFT-LCD panels worldwide including in the United States, and millions of dollars of profits for the cartelists. The appellants were Taiwanese company AU Optronics (AUO), AUOA, AUO's retailer and wholly owned subsidiary, and two executives from AUO. While Appellants asserted multiple grounds to challenge their convictions - all of which were rejected - this article focuses on their challenges based on the FTAIA, specifically their argument that because "the bulk of the panels were sold to third parties worldwide rather than for direct import into the United States, the nexus to United States commerce was insufficient under the Sherman Act as amended by the" FTAIA.
In its July 10, 2014 opinion, the Ninth Circuit determined that it did not need to "resolve whether the evidence of the defendants' conduct was sufficiently 'direct' or whether it 'gives rise to an antitrust claim,' because, as we noted earlier, 'any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt,' with respect to import trade." 758 F.3d at 1094 (citations omitted, emphasis in original).
In the Amended Order, the Ninth Circuit explicitly addressed this domestic effects test, holding "[l]ooking at the conspiracy as a whole, and recognizing the standard on appeal is whether 'any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt,' [ ] we conclude that the conduct was sufficiently 'direct, substantial, and reasonably foreseeable with respect to the effect on United States commerce." Opinion at 41. In "looking at the conspiracy as a whole, the Ninth Circuit noted that:
- TFT-LCDs are a substantial cost component of finished products.
- The cartel's secret meetings and agreements in furtherance of the conspiracy "led to direct negotiations with United States companies, both domestically and overseas, on pricing decisions." Opinion at 42.
- Some panels were sold overseas to foreign subsidiaries of American companies or to systems integrators and incorporated into finished products, and it was "understood" that substantial numbers of these finished products were destined for the United States and thus "the practical upshot of the conspiracy would be and was increased prices to customers in the United States." Opinion at 42.
The Ninth Circuit elaborated on point three with examples of (1) panel purchaser Dell having a factory in Malaysia where 100% of the products were destined for American markets, (2) foreign systems integrators purchasing panels for integration into finished products with direct oversight of TFT-LCD pricing by United States manufacturers, (3) the global product arm of a United States company purchasing price-fixed panels from a defendant and selling them to systems integrators, and (4) system integrators purchasing panels from defendants based on custom orders from United States companies. Based on these factors, the court found an "integrated, close and direct connection between the purchase of the price-fixed panels, the United States as the destination for the products, and the ultimate inflation of prices in finished products imported to the United States." Opinion at 43. The court concluded that this direct connection was "neither speculative nor insulated by multiple disconnected layers of transactions." Id. The court further distinguished the facts before it from the claimed domestic effect which was deemed insufficient in United States v. LSL Biotechnologies, 379 F.3d 672 (9th Cir. 2004), describing that claim as "resting on speculation as to future innovation in tomato seeds and lack[ing] an existing effect on American tomato customers." Opinion at 43.
The court directly addressed the recent Seventh Circuit decision in Motorola Mobility LLC v. AU Optronics Corp., 2014 U.S. App. LEXIS 22408 (7th Cir. November 26, 2014), which arose from the same cartel and applied the FTAIA in granting summary judgment to the defendants. That opinion was discussed in the Antitrust Section's January 2015 e-brief. The court indicated that its ruling was consistent with Motorola because the "private" claim in Motorola ultimately failed due to the bar against indirect purchaser claims of Illinois Brick Co. v. Illinois, 431 U.S. 720 (1977). The Ninth Circuit also noted that the Seventh Circuit in Motorola had indicated that the United States could pursue criminal charges and injunctive relief provided that the requisite statutory effects were present.
The Ninth Circuit also noted in a footnote that both the Second Circuit and the Seventh Circuit disagree with the Ninth Circuit's more stringent definition of "direct effects" for purposes of the FTAIA. The Ninth Circuit has held that an effect is "direct" if it "follows as an immediate consequence of the defendant's activity", United States v. LSL Biotechnologies, 379 F.3d 672, 692 (9th Cir. 2004). The Second Circuit has held that the direct effects test requires only a "reasonably proximate causal nexus", Lotes Co., Ltd. v. Hon Hai Precision Industry Co., Ltd, 753 F.3d 395, 398 (2d Cir. 2014) while the Seventh Circuit has held that "[s]uperimposing the idea of 'immediate consequence' on top of the full phrase results in a stricter test than the complete statute can bear." Minn-Chem, Inc. v. Agrium, Inc., 683 F.3d 845, 857 (7th Cir. 2012). In the Amended Order, the Ninth Circuit stated that whether it should reconsider "the stricter standard we impose is not within the province of this panel because a three judge panel may not overrule a prior decision of the court" while noting that "in any event, the result is the same and the defendants benefit from our circuit's formulation." Opinion at 41 n. 9.
Cotchett, Pitre & McCarthy, LLP
California Antitrust and Unfair Competition Law, Revised Edition
Cheryl Lee Johnson, Editor-in-Chief
Gain authoritative understanding of California antitrust and unfair competition statutes, policies and issues with one-volume convenience. This treatise brings you up to speed on everything from horizontal combinations and vertical restraints to public enforcement of California antitrust laws and trial considerations.
You get full coverage of The Cartwright Act along with related California consumer and unfair competition laws, and how they apply to the health industry, regulated industries, the labor market, electronic media, the internet and other fields. Additionally, there are chapters covering damages, defenses to liability including exemptions and immunities, injunctive relief, class actions, attorney’s fees and costs, insurance issues, and much more. This publication includes contributions from over 120 highly experienced antitrust practitioners in both the private and government sectors, as well as the executive members of the Antitrust and Unfair Competition Law Section of the California State Bar.
$260, 1 volume, loose-leaf, updated annually, Pub. #01577, ISBN 9780769856896
To order, call 800-223-1940 or visit the LexisNexis Store.
Antitrust & Unfair Competition Section
The State Bar of California
180 Howard Street
San Francisco, CA 94105-1639