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Antitrust Keyed to Areeda, 8th Ed.
Monsanto Co. v. Spray-Rite Service Corp.
Citation:
465 U.S. 752 (1984)Facts
Spray-Rite was a discount distributor of agricultural chemicals from 1955 to 1972 and an authorized Monsanto distributor from 1957 to 1968. In October 1967, Monsanto announced new criteria for renewing distributorships, including whether distributors employed trained salesmen and could fully exploit their market areas. In 1968, Monsanto declined to renew Spray-Rite’s distributorship. At that time, Spray-Rite was the 10th largest distributor of Monsanto’s corn herbicide, with 16% of its sales being Monsanto products. After termination, Spray-Rite continued as a herbicide dealer until 1972 but had limited access to Monsanto products. Evidence showed that competing distributors had complained about Spray-Rite’s price-cutting, and a Monsanto official allegedly stated that Spray-Rite was terminated because of these complaints. There was also evidence of Monsanto threatening other price-cutting distributors with termination if they did not maintain suggested prices.
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