ZF Meritor, LLC v. Eaton Corp.
United States Court of Appeals for the Third Circuit
696 F.3d 254 (2012)
Eaton Corporation (Eaton) (defendant) was the leading manufacturer of heavy-duty (HD) truck transmissions. Eaton signed long-term agreements with each of the four HD transmission purchasers in North America (purchasers). The agreements provided rebates to the purchasers if they purchased from Eaton a specified percentage of their overall HD transmission needs. Two of the agreements allowed Eaton to terminate if the purchaser did not meet the specified percentage. Additionally, each agreement required the purchaser to publish Eaton as the standard HD transmission offering in its data book, a key reference source for truck buyers. Two of the agreements required the purchasers to remove Eaton’s competitors’ equipment from the purchasers’ data books. Finally, the agreements required the purchasers to offer preferential pricing for Eaton’s transmissions. ZF Meritor, LLC and Meritor Transmission Corporation (collectively, ZF) (plaintiffs) were competitors of Eaton. After Eaton signed the agreements, ZF had a market share of 8 percent. ZF brought an antitrust suit against Eaton alleging that Eaton had used its dominant market position to induce the purchasers into entering de facto exclusive dealing agreements. ZF’s market share further declined after it filed suit, and ZF eventually left the market. After a trial, the jury found in ZF’s favor. The district court denied Eaton’s motion for judgment as a matter of law, and Eaton appealed. On appeal, Eaton did not dispute that it had monopoly power in the relevant market, but it argued that ZF failed to prove anticompetitive conduct because ZF did not show that Eaton had priced its transmissions below its costs.
Rule of Law
Holding and Reasoning (Fisher, J.)
Dissent (Greenberg, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 176,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.