Not Horsing Around
On Tuesday, the 11th Circuit affirmed the district court’s grant of summary judgment in favor of the defendants in JES Properties v. USA Equestrian. The 11th Circuit stated that the district court had:
concluded that (1) each defendant was entitled to implied immunity from antitrust liability; (2) JES and Mr. Gallagher lacked antitrust standing; (3) JES and Mr. Gallagher failed to present evidence of concerted action; and (4) the Rule of Reason applied to the USEF’s and the Promoter Defendants’ actions, and their actions were not an unreasonable restraint of trade.
that the USEF and the Promoter Defendants are entitled to implied immunity. We address standing briefly, but we do not reach the other issues raised by JES and Mr. Gallagher.
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