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United States v. American Can Co.
United States District Court for the District of Maryland
230 F. 859 (1916)
American Can Company (American Can) (defendant) was a leader in the market for tin cans. In 1899, American Can began purchasing market competitors, generally inducing the purchases by offering sums well above the value of the acquired assets. Additionally, American Can had an association with a tin-plate provider, and there was a fear among can makers that a refusal to sell out to American Can would ultimately force the can makers out of business, as the can makers would not be able to acquire raw material necessary to make the cans. Eventually, American Can acquired enough competitors to raise the prices of cans. The United States (plaintiff) brought a complaint against American Can, claiming that American Can’s actions in obtaining the large market share violated the Sherman Antitrust Act’s prohibition on unlawful attempts to monopolize an industry. American Can argued that American Can had operated lawfully for many years and that its market strength had allowed American Can to create new product standards and efficiencies that greatly benefitted customers.
Rule of Law
Holding and Reasoning (Rose, J.)
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