Section 2 refusal-to-deal liability may survive despite intellectual property defenses when the justification is shown pretextual.

A monopolist may face Section 2 liability for exclusionary refusal to deal under ordinary antitrust principles, and the essential facilities doctrine is not the sole basis for such claims. The text also treats intellectual property ownership as a presumptively valid business justification, but one that can be rebutted by pretext or anticompetitive use. It further explains that market definition may turn on commercial realities, including access to all parts needed to compete in downstream service markets, and that monopoly power and entry barriers may be shown by control of designs, tools, patents, brand power, and contractual restraints. Damages and injunctive relief require evidentiary support and tailoring to lawful intellectual property interests.

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Issues: (i) whether the relevant parts market could be defined on an "all parts" basis and whether the evidence established monopoly power and entry barriers under Section 2 of the Sherman Act; (ii) whether a monopolist's unilateral refusal to deal could be assessed under traditional Section 2 principles without confining liability to the essential facilities doctrine, including the effect of intellectual property rights as a business justification; (iii) whether juror bias required reversal; and (iv) whether the damages awards for lost service profits and used equipment sales were supported, and whether the permanent injunction required modification.

Issue (i): whether the relevant parts market could be defined on an "all parts" basis and whether the evidence established monopoly power and entry barriers under Section 2 of the Sherman Act.

Analysis: The relevant market inquiry turned on commercial realities rather than abstract interchangeability. For Kodak equipment, service providers needed access to all parts to compete in the downstream service market, and the evidence supported treating the aggregate of parts for each equipment line as a single market. The record also supported a dominant market share and significant entry barriers, including control of designs, tools, patents, brand power, contractual restraints, and inability of competitors to expand rapidly enough to discipline pricing.

Conclusion: The market definition, monopoly power finding, and entry-barrier analysis were upheld, and these issues were decided against the appellant.

Issue (ii): whether a monopolist's unilateral refusal to deal could be assessed under traditional Section 2 principles without confining liability to the essential facilities doctrine, including the effect of intellectual property rights as a business justification.

Analysis: The refusal-to-deal claim was evaluated under ordinary Section 2 principles drawn from refusal-to-deal and exclusionary-conduct precedents. The essential facilities doctrine was not treated as the exclusive route to liability. The Court accepted that patent and copyright ownership may supply a presumptively valid business justification, but that presumption is rebuttable by pretext or other evidence showing anticompetitive use of the protected rights. The jury instructions were largely sustained, though the injunction was modified to preserve the value of Kodak's protected rights while preventing continuation of exclusionary conduct.

Conclusion: Liability on the refusal-to-deal and leveraging theories was sustained, and the intellectual property defense did not defeat the antitrust claims.

Issue (iii): whether juror bias required reversal.

Analysis: The challenged juror disclosed prior adverse dealings with Kodak, but after questioning assured the court that he could decide the case fairly and on the evidence. The trial judge's assessment of impartiality was entitled to deference absent actual bias or abuse of discretion.

Conclusion: No reversible juror bias was shown, and the challenge failed.

Issue (iv): whether the damages awards for lost service profits and used equipment sales were supported, and whether the permanent injunction required modification.

Analysis: The service-damages awards were largely supported by substantial evidence and acceptable yardstick methodologies, though the damages awarded to one ISO lacked adequate support. The used-equipment damages were not properly segregated from conduct that had not been adjudicated unlawful and required a new trial. The injunction was too broad in requiring sale of all parts at reasonable prices; it was narrowed to Kodak-manufactured parts and modified to remove the reasonable-pricing requirement while preserving nondiscriminatory access and the ability to protect intellectual property rights.

Conclusion: The service-damages awards were largely affirmed, one damages award was reversed, the used-equipment damages were remanded for a new trial, and the injunction was affirmed as modified.

Final Conclusion: The decision sustained liability under Section 2 in substantial part, preserved most damages and injunctive relief, but narrowed the remedial order and required further proceedings only on the unsupported damages component.

Ratio Decidendi: A monopolist may be liable under Section 2 for exclusionary unilateral refusal to deal when the conduct lacks a legitimate business justification, and intellectual property rights create only a rebuttable justification that must yield to proven pretext or anticompetitive use.

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