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Antitrust Keyed to Areeda, 8th Ed.
Eastman Kodak Co. v. Image Technical Services, Inc.
Citation:
504 U.S. 451 (1992)Facts
Eastman Kodak manufactured and sold complex photocopiers and micrographic equipment. Kodak also sold service and replacement parts for its machines, producing some parts itself and purchasing others from independent manufacturers (OEMs). Beginning in the early 1980s, Independent Service Organizations (ISOs) began repairing and servicing Kodak equipment, often at lower prices than Kodak charged. In 1985 and 1986, Kodak implemented policies to limit the availability of parts to ISOs by: (1) selling replacement parts only to buyers who used Kodak service or repaired their own machines, (2) securing agreements with OEMs not to sell parts to ISOs, and (3) pressuring equipment owners not to sell parts to ISOs. These policies made it difficult for ISOs to compete in servicing Kodak equipment, forcing many out of business and compelling customers to switch to Kodak service despite preferring ISO service. The ISOs sued Kodak, alleging violations of Sections 1 and 2 of the Sherman Act.
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