In re Capacitors Antitrust Litigation
106 F. Supp. 3d 1051
N.D. Cal.2015Background
- Consolidated antitrust actions allege price-fixing in the capacitor market by multiple international manufacturers.
- DPPs claim a single overarching conspiracy across electrolytic and film capacitors from 2003 to present; IPPs allege two conspiracies with different periods.
- Plaintiffs seek Sherman Act relief, treble damages under the Clayton Act, and injunctions; IPPs also invoke California Cartwright Act and UCL.
- Defendants move to dismiss for lack of plausibility, standing, and California-law nationwide application issues; some U.S. subsidiaries are challenged.
- Court declines total dismissal, allowing amendment; some entities dismissed with leave to amend; ACPERA/leniency considerations excluded from pleading weight.
- Court emphasizes Twombly/Iqbal standards and differentiates between pleading sufficiency and ultimate proof of conspiracy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Pleading plausibility of DPP price-fixing claim | DPPs rely on Panasonic/SANYO admissions to plead conspiracy. | Allegations are too broad/conclusory; single overarching conspiracy implausible. | DPPs’ complaint plausible under Twombly; not dismissed. |
| Standing and pleading two conspiracies for IPPs | IPPs allege two conspiracies and overlap with DPPs; claims should survive. | Standing and scope fail under California/other rules; requires more specificity. | IPPs survive standing challenges; dismissal narrowly limited to some pleadings; California-law issues addressed later. |
| Nationwide California-law claims | California law statewide claims can be applied nationwide under certain logic. | Shutts requires limited national application due to conflicts and contacts. | Nationwide class claims under California law stricken; effects limited to states with similar laws. |
| Unjust enrichment as a standalone claim | Unjust enrichment is a remedy, not separate claim; should survive. | Unjust enrichment is not an independent cause of action. | Unjust enrichment dismissed with prejudice as standalone claim. |
| Membership and role of defendants; successor liability | Subsidiaries and corporate families participated; need not plead every role in detail. | Lack of specific, non-conclusory linkage to conspiratorial acts warrants dismissal. | Many U.S. subsidiaries dismissed with leave to amend; others allowed to proceed; some subsidiaries' links sustained. |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (pleading must show plausible grounds to infer agreement)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (pleading requires more than mere conclusory statements)
- In re TFT-LCD (Flat Panel) Antitrust Litig., 586 F. Supp. 2d 1109 (N.D. Cal. 2008) (applies Twombly pleading standards to antitrust conspiracy aboard)
- In re Graphics Processing Units Antitrust Litig., 527 F. Supp. 2d 1011 (N.D. Cal. 2007) (standing and pleading in complex antitrust actions)
- Samsung Electronics Co. v. Panasonic Corp., 747 F.3d 1199 (9th Cir. 2014) (California antitrust standing and interpretation changes)
- Aryeh v. Canon Bus. Solutions, Inc., 55 Cal.4th 1185 (Cal. 2013) (California antitrust interpretation not wholly bound to federal law)