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Keywords

injunctionappealtrialtrustantitrust
plaintiffdefendantdamagesinjunctionwill

Related Cases

Interphoto Corp. v. Minolta Corp., 417 F.2d 621

Facts

The action was initiated under Section 16 of the Clayton Act against a manufacturer of imported photographic equipment by a former distributor whose agreement had been terminated. The distributor claimed that the manufacturer violated antitrust laws by attempting to control prices and territories. The district court issued a temporary injunction against the manufacturer's refusal to deal, which led to the appeal by the manufacturer, challenging the findings of fact regarding the termination and the conclusions about irreparable injury.

The late Judge Herlands, in January 1969, issued a temporary injunction against the manufacturer's refusal to deal, 295 F.Supp. 711.

Issue

Did the trial court err in finding that the manufacturer terminated the distributorship due to the distributor's failure to follow directions, and was the issuance of a temporary injunction justified to prevent irreparable injury to the distributor?

However, the original order, relying on United States v. Arnold, Schwinn & Co., 388 U.S. 365, 87 S.Ct. 1856, 18 L.Ed.2d 1249 (1967), forbade the defendant to impose territorial restrictions on plaintiff's resale.

Rule

The court applied the 'unless clearly erroneous' rule to the findings of fact and assessed whether the trial court's conclusions regarding irreparable injury were justified based on the circumstances.

The former finding is one of fact and thus within the ambit of the ‘unless clearly erroneous' rule. F.R.Civ.P. 52(a).

Analysis

The Court of Appeals found that the trial court was within its rights to accept the distributor's claims regarding irreparable injury, particularly given the relatively slight harm that a temporary injunction would cause the manufacturer. The court noted that the manufacturer did not contest the conclusion that its actions constituted per se violations of antitrust laws and that the findings regarding the termination of the distributorship were factual determinations that were not clearly erroneous.

With respect to irreparable injury, while the judge was not obliged to accept plaintiff's contention that it would be unable to calculate its damages since it would suffer not merely loss of profits with respect to Minolta's goods but loss of good will from the lack of a ‘full line,’ he was free to do so, especially in light of the relatively slight harm a temporary injunction would cause the defendant.

Conclusion

The Court of Appeals affirmed the district court's decision, upholding the temporary injunction against the manufacturer and the findings regarding the termination of the distributorship.

Affirmed.

Who won?

The distributor prevailed in the case because the court found that the manufacturer’s termination of the distributorship was based on violations of antitrust laws and that the distributor would suffer irreparable harm without the injunction.

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