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Keywords

plaintiffdamagestrustcorporationantitrustcivil proceduredeterrence
plaintiffdamagescorporation

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Comcast Corp. v. Behrend, 569 U.S. 27, 133 S.Ct. 1426, 185 L.Ed.2d 515, 81 USLW 4217, 2013-1 Trade Cases P 78,316, 85 Fed.R.Serv.3d 118, 13 Cal. Daily Op. Serv. 3396, 2013 Daily Journal D.A.R. 4027, 57 Communications Reg. (P&F) 1487, 24 Fla. L. Weekly Fed. S 125

Facts

The case arose from allegations that Comcast Corporation and its subsidiaries engaged in anti-competitive practices by clustering their cable operations in the Philadelphia area, which allegedly harmed subscribers by reducing competition and leading to higher prices. The plaintiffs sought class certification under Federal Rule of Civil Procedure 23(b)(3), claiming that Comcast's actions lessened competition from overbuilders and resulted in supra-competitive prices. The District Court initially certified the class based on one of the plaintiffs' theories of antitrust impact, but the regression model used to calculate damages did not isolate damages from that specific theory.

The case arose from allegations that Comcast Corporation and its subsidiaries engaged in anti-competitive practices by clustering their cable operations in the Philadelphia area, which allegedly harmed subscribers by reducing competition and leading to higher prices.

Issue

Did the lower courts err in certifying a class under Rule 23(b)(3) when the plaintiffs' damages model failed to demonstrate that damages were susceptible to measurement across the entire class?

Did the lower courts err in certifying a class under Rule 23(b)(3) when the plaintiffs' damages model failed to demonstrate that damages were susceptible to measurement across the entire class?

Rule

To certify a class under Rule 23(b)(3), the court must find that questions of law or fact common to class members predominate over any questions affecting only individual members, and that the party seeking certification must provide evidentiary proof that these requirements are met.

To certify a class under Rule 23(b)(3), the court must find that questions of law or fact common to class members predominate over any questions affecting only individual members, and that the party seeking certification must provide evidentiary proof that these requirements are met.

Analysis

The Supreme Court found that the Third Circuit erred by not considering the arguments against the plaintiffs' damages model that were relevant to class certification. The regression model did not isolate damages attributable to the only accepted theory of antitrust impact, which was the deterrence of overbuilders. As a result, the model could not establish that damages were measurable on a class-wide basis, leading to the conclusion that individual damage calculations would overwhelm common questions.

The Supreme Court found that the Third Circuit erred by not considering the arguments against the plaintiffs' damages model that were relevant to class certification.

Conclusion

The Supreme Court reversed the lower courts' decision to certify the class, concluding that the plaintiffs failed to demonstrate that damages could be measured on a class-wide basis as required under Rule 23(b)(3).

The Supreme Court reversed the lower courts' decision to certify the class, concluding that the plaintiffs failed to demonstrate that damages could be measured on a class-wide basis as required under Rule 23(b)(3).

Who won?

Comcast Corporation prevailed in the case because the Supreme Court determined that the plaintiffs' damages model was insufficient to support class certification under Rule 23(b)(3).

Comcast Corporation prevailed in the case because the Supreme Court determined that the plaintiffs' damages model was insufficient to support class certification under Rule 23(b)(3).

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