Alan's of Atlanta, Inc. v. Minolta Corp.

903 F.2d 1414 (1990)

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Alan’s of Atlanta, Inc. v. Minolta Corp.

United States Court of Appeals for the Eleventh Circuit
903 F.2d 1414 (1990)

Facts

Alan’s of Atlanta, Inc. (AA) (plaintiff) was a specialty store that sold cameras and camera equipment. Minolta Corp. (defendant) manufactured cameras, and it was one of the biggest brand cameras that AA sold. As of 1979, AA accounted for about 33 percent of the sales of Minolta cameras in the Atlanta market. But then Minolta decided to implement what it termed a key-dealer program in which it provided free cameras, free advertising, and similar benefits for particular camera dealers. It declined to select AA as a key dealer. Instead, it selected Wolf Camera, Inc., for this role. At the time, in 1979, Wolf Camera accounted for only 6 percent of Minolta camera sales. But by 1985, Wolf Camera accounted for 29 percent of Minolta camera sales due to being a key dealer. AA, meanwhile, saw its share of Minolta camera sales during this same period drop from 33 percent to 4 percent. AA brought suit against Minolta for violating the Robinson-Patman Act. The district court concluded that AA could not prove it had suffered an antitrust injury under the Robinson-Patman Act and dismissed the case for lack of standing at the summary-judgment stage. AA appealed.

Rule of Law

Issue

Holding and Reasoning (Eschbach, J.)

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