In Re TFT-LCD (Flat Panel) Antitrust Litigation, 3:07-md-01827

Background

Multidistrict antitrust litigation alleging a global price‑fixing conspiracy in TFT‑LCD panels; several plaintiffs bring Florida state‑law claims (Tech Data, TracFone, Office Depot, Brandsmart).
Plaintiffs were headquartered in Florida and placed orders, negotiated, and paid for the LCD products from Florida.
Defendants Chunghwa Picture Tubes, Ltd. (CPT) and HannStar are Taiwanese manufacturers that never maintained offices in Florida or California and never sold directly to these plaintiffs.
Defendants moved for summary judgment arguing that applying Florida law to their conduct would violate due process because they lacked contacts with Florida.
Plaintiffs relied on the location of their purchases and injuries in Florida and Florida’s interest in protecting its residents from anticompetitive conduct; they also asserted claims under the Florida Deceptive and Unfair Trade Practices Act (FDUTPA).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether applying Florida law violates due process	Plaintiffs: purchases, negotiations, payments, and injuries occurred in Florida, giving Florida significant contacts and interests	Defendants: they had no contacts or conspiratorial conduct in Florida; applying Florida law would be arbitrary and expose them to every state where products were sold	Denied — Florida has sufficient contacts and interests; Allstate standard met
Relevance of defendants' lack of direct sales to plaintiffs in Florida	Plaintiffs: not dispositive; the conspiracy affected prices of goods bought in Florida so injury occurred in Florida	Defendants: absence of sales or conduct in Florida means Florida law should not apply	Denied — place of purchase and injury in Florida are sufficient despite lack of direct sales
Whether plaintiffs must show the panels they bought were manufactured by these defendants	Plaintiffs: unnecessary because the conspiracy raised prices across products; plaintiffs were injured in Florida by price‑fixed goods	Defendants: plaintiffs failed to show their purchases contained defendants' panels, so Florida law shouldn’t apply	Denied — causation and injury in Florida from the price‑fixing conspiracy suffice for due process analysis
Applicability of FDUTPA to these claims	Plaintiffs: FDUTPA's text and liberal construction permit application to out‑of‑state conduct causing injury to Florida consumers	Defendants: FDUTPA applies only to conduct occurring within Florida	Denied — FDUTPA does not restrict claims to acts entirely within Florida and can apply to plaintiffs' claims

Key Cases Cited

Allstate Ins. Co. v. Hague, 449 U.S. 302 (due process requires significant contacts with the state whose law is applied)
AT&T Mobility LLC v. AU Optronics Corp., 707 F.3d 1106 (9th Cir.) (Allstate is permissive; place of purchase relevant in price‑fixing cases)
Phillips Petroleum Co. v. Shutts, 472 U.S. 797 (forum‑state choice‑of‑law limits are modest)
Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burdens and standards)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (nonmoving party must show more than metaphysical doubt)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (jury must have sufficient evidence to favor nonmoving party)
In re Florida Cement & Concrete Antitrust Litig., 746 F. Supp. 2d 1291 (FDUTPA and antitrust context)
In re Flonase Antitrust Litig., 692 F. Supp. 2d 524 (refusing to limit FDUTPA to purely in‑state acts)