Eastern Auto Distributors, Inc. v. Peugeot Motors of America, Inc.

Automobiles Peugeot, S.A. (defendant) was the sole manufacturer of all Peugeot vehicles worldwide. Peugeot Motors of America, Inc. (PMA) (defendant) imported all Peugeot vehicles into the United States. PMA originally had the practice of selling the imported Peugeot vehicles to intermediate distributors. The intermediate distributors, in turn, had the exclusive right to sell the Peugeot vehicles to retail Peugeot dealers in various geographic areas of the country. PMA eventually absorbed all the intermediate distributors—save one—into itself and took over distributing the vehicles to local retailers. PMA allowed only one intermediate distributor to continue operating—Eastern Auto Distributors, Inc. (EAD) (plaintiff). EAD operated in the southeast region of the country. PMA provided certain cash incentives and training facilities to its own retail dealers, but it declined to provide these things to EAD’s retail dealers. There was no evidence of any geographic competition between PMA’s retail dealers and EAD’s local dealers. Although there were approximately 800 cross-border sales, it was undisputed that these sales were for reasons other than geographic competition. EAD brought suit against PMA and Automobiles Peugeot for violating the Robinson-Patman Act. After EAD presented its case at trial, the district court granted a directed verdict in favor of PMA and Automobiles Peugeot. EAD appealed.