Franchising (& Distribution) Currents

[...] the court concluded that the franchisee had failed to allege that Trane's bundling policies had an anticompetitive effect on the tied product market for non-Trane products. The court found unpersuasive plaintiffs' claim that the franchisor's market power should be defined by the contractual franchise relationship. Because a tying claim generally requires that a defendant's economic power be derived from the market rather than plaintiffs' voluntary contractual relationship, plaintiffs' failure to allege market power in the relevant market was grounds for dismissal of the antitrust complaint.