Antitrust Guide to Market Arrangements


Advancing a horizontal or vertical arrangement whose purpose is to foreclose rivals from access to markets.

EXAMPLE: Lorain Journal
In Lorain Journal, a newspaper published in Lorain, Ohio, “enjoyed a substantial monopoly in Lorain of the mass dissemination of news and advertising, both of a local and national character.” It had a 99% coverage of Lorain families. “Those factors made the Journal an indispensable medium of advertising for many Lorain concerns.” The establishment of a radio station in Elyria, Ohio, eight miles south of Lorain, created a challenge to the newspaper monopoly. To “eliminate the threat of competition,” the newspaper refused to accept local advertisements in from any advertiser who advertised with the radio station. The Supreme Court held that this refusal to deal policy was an unlawful attempt to monopolize in the meaning of Section 2 of the Sherman Act.

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