Aladdin's Lights, Inc. v. Eye Lighting Internatl.
2017 Ohio 7229
| Ohio Ct. App. | 2017Background
- Aladdin’s Lights, a retail distributor, sold Hortilux grow lamps manufactured by EYE Lighting; Aladdin’s owner is a former EYE employee.
- Aladdin alleged that, beginning July 1, 2010, EYE and its master distributors implemented a Minimum Advertised Price (MAP) and Minimum Selling Price (MSP) scheme and cut off resellers who refused to comply.
- Aladdin refused to comply, alleges EYE and distributors refused to sell to it, and claims resulting lost sales and overcharges to consumers from the alleged vertical price-fixing and group boycott.
- Aladdin sued under Ohio’s Valentine Act (state antitrust law) seeking injunctive relief and damages; discovery and motions followed, including a protective order and cross-motions for summary judgment.
- The trial court granted EYE’s summary judgment, holding Aladdin was an indirect purchaser and thus lacked standing under the Illinois Brick direct-purchaser rule; Aladdin appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing under Valentine Act (direct vs. indirect purchaser) | Aladdin argued it could pursue claims despite being an indirect purchaser and invoked exceptions (e.g., co-conspirator theory). | EYE argued Aladdin never bought directly from EYE (only through distributors), so Illinois Brick/Valentine Act bars recovery by indirect purchasers. | Court held Aladdin was an indirect purchaser and lacked standing; summary judgment for EYE affirmed. |
| Applicability of co-conspirator exception to Illinois Brick | Aladdin asserted a vertical conspiracy with distributors makes it a direct purchaser under a co-conspirator doctrine. | EYE argued no recognized exception under Ohio law and Aladdin remained indirect purchaser. | Court rejected the co-conspirator exception because Ohio has not adopted it; Aladdin’s argument failed. |
| Trial court’s protective order over sensitive documents | Aladdin argued protective order improper (claimed abuse of discretion). | EYE sought protection to limit use of sensitive business documents to litigation. | Court declined to reach this issue as moot after resolving standing; lower-court ruling left intact. |
| Denial of Aladdin’s partial summary judgment | Aladdin sought partial SJ on liability; argued evidence established EYE liability. | EYE maintained Aladdin lacked standing and other defenses. | Court found issue moot after concluding Aladdin lacked standing and affirmed denial. |
Key Cases Cited
- Grafton v. Ohio Edison Co., 77 Ohio St.3d 102 (1996) (standard of appellate review for summary judgment)
- Murphy v. Reynoldsburg, 65 Ohio St.3d 356 (1992) (summary judgment: view facts most favorably to nonmovant)
- Dresher v. Burt, 75 Ohio St.3d 280 (1996) (movant’s initial burden in summary judgment and burden-shifting)
- State ex rel. Zimmerman v. Tompkins, 75 Ohio St.3d 447 (1996) (nonmovant’s reciprocal burden to show genuine issue)
- C.K. & J.K., Inc. v. Fairview Shopping Ctr. Corp., 63 Ohio St.2d 201 (1980) (Valentine Act interpreted consistent with federal antitrust law)
- Johnson v. Microsoft Corp., 106 Ohio St.3d 278 (2005) (Ohio follows Illinois Brick rule limiting antitrust suits to direct purchasers)
- Illinois Brick Co. v. Illinois, 431 U.S. 720 (1977) (direct-purchaser rule barring indirect purchasers from private antitrust actions)
- N. Pacific Ry. Co. v. United States, 356 U.S. 1 (1958) (examples of anticompetitive practices)
- N.H.L. Players’ Assn. v. Plymouth Whalers Hockey, 325 F.3d 712 (6th Cir. 2003) (combination by two or more actors necessary to show restraint of trade)
- McCarthy v. Recordex Service, Inc., 80 F.3d 842 (3d Cir. 1996) (rationale for Illinois Brick bright-line rule)
- In re ATM Fee Antitrust Litig., 686 F.3d 741 (9th Cir. 2012) (discussion of co-conspirator exception to Illinois Brick)