Omega Environmental, Inc. v. Gilbarco, Inc.

Gas-dispensing-equipment manufacturers in the United States sold their equipment to businesses both directly and indirectly through authorized distributors. Competition in this market was fierce among a few manufacturers. One manufacturer, Gilbarco, Inc. (defendant), sold most of its equipment indirectly through authorized distributors with which it had agreements. In 1991, a group of entrepreneurs created Omega Environmental Incorporated (Omega) (plaintiff). Omega was not an equipment manufacturer like Gilbarco. Instead, Omega sought to create a national network of “one-stop shopping” through which businesses could buy gas-dispensing equipment from all the manufacturers, including Gilbarco. Omega sought to acquire several distributors that sold Gilbarco equipment. In response, Gilbarco ended its distribution agreements with the distributors that Omega acquired. In effect, Gilbarco required its distributors to exclusively deal with Gilbarco equipment and not the equipment of other manufacturers. Omega sued Gilbarco for various state and federal antitrust-related claims. The district court dismissed many of the claims before trial. The court did not, however, dismiss Omega’s exclusive-dealing claim under the Clayton Act. The jury returned a verdict in favor of Omega. After trial, Gilbarco moved for judgment as a matter of law. The court denied the motion, and Omega appealed.