neochart v2 research

cases/15usc1/f-supp-3d-377-506-premier-comp-v-upmc.case

Source: cases/15usc1/f-supp-3d-377-506-premier-comp-v-upmc.case

Case source: https://www.neochart.com/catalog/cases/f-supp-3d/volume_377/0506_01/index.html

Verbatim annotated passages

In order to succeed in showing antitrust standing, a Section 1 violation or a Section 2 violation, a plaintiff must prove the existence of a properly-defined relevant product and geographic market.
Premier's failure to define the relevant markets in this instance dooms its antitrust claims, and will result in summary judgment in favor of Defendants.

Exact source text

casedsl 1.2
# author: Flash1 (gemini-3.8-flash-high)
# triaged-by: Fable (2026-11-10)

case /f-supp-3d/377/0506-01
  name    Premier Comp Solutions LLC v. UPMC
  cite    377 F. Supp. 3d 506 (2019)
  court   United States District Court for the Western District of Pennsylvania
  date    2019-03-27
  url     catalog/cases/f-supp-3d/volume_377/0506_01/index.html
  source  ir/caselaw/f_supp_3d_377.jsonl sha1=5e3c9730ef7e56bdef79ab52e7287c7c9963756d chars=60000

opinion op : order by Cercone @0..60000 controlling
? opinion: the IR text is capped at 60000 chars and stops a few sentences into Part IV.C (antitrust standing / antitrust injury). The market-definition ruling (Part IV.B) is complete; the court's own rulings on antitrust injury, on concerted action under § 1 and on § 2 lie beyond the cap and are NOT recorded here.

party premier : Premier Comp Solutions, LLC (workers' compensation cost-containment vendor; plaintiff)
party defendants : UPMC, UPMC Benefit Management Services and UPMC Health Benefits (d/b/a WorkPartners), and MCMC, LLC (repricing vendor) (defendants)
theory sec1 : § 1 counts II (group boycott), IV (exclusive dealing) and V (restraint of trade): WorkPartners consolidated repricing with MCMC and moved panel generation to Align, cutting Premier out

law 15usc1
  role    applied
  posture civil; cost-containment vendor sued an insurer/TPA, its parent and a rival vendor under Sherman Act §§ 1 and 2 after losing the insurer's business; after discovery, defendants' motions for summary judgment granted: plaintiff failed to establish a relevant product or geographic market
  result  claimant-lost

element restraint.rule-of-reason : not-satisfied [no-evidence]
  party   premier defendants
  theory  sec1
  route   market-definition
  pattern expert-asserted "cluster" product market and regional geographic market with no quantitative or practical-indicia support
  rule @56198..56395 | In order to succeed in showing antitrust standing, a Section 1 violation or a Section 2 violation, a plaintiff must prove the existence of a properly-defined relevant product and geographic market.
  fact @45864..46122 [cuts-against absent] | In defining the relevant product market, however, Premier fails to direct this Court to any evidence with regard to the Brown Shoe factors, any "practical indicia" that defines the boundaries of the relevant market, or the "business realities" of the market.
  fact @49188..49326 [cuts-against] | In this instance, none of the competitors identified by Premier offer the same set of services as those Premier included in the "cluster."
  fact @51789..51942 [supports] | Steve Wagner, the Senior Claims Manager for WP, agreed that panel development by and for [WorkPartners] would generally have been confined to Western PA.
  fact @54107..54243 [cuts-against] | Premier's expert, Dr. Fuhr, testified that the markets for repricing, physical therapy networks, and MRI networks are national in scope.
  held @56924..57077 | Premier's failure to define the relevant markets in this instance dooms its antitrust claims, and will result in summary judgment in favor of Defendants.
  gloss Summary judgment after "years of discovery": both the proposed cluster product market and the western-Pennsylvania geographic market are rejected for want of evidence (the court's own label is "legally insufficient"). The same failure is held fatal to antitrust standing and to the § 2 counts.
  ? basis: the court says "legally insufficient" (Queen City Pizza language) but rests on the absence of record evidence at summary judgment, so [no-evidence] rather than [law].
  ? other: the law file also declares `restraint.market-power`; recorded here under rule-of-reason / market-definition because the route menu places proof of a plausible relevant market there.
  ? polarity: the Wagner testimony reaches the court only through a block quote of Premier's brief; the court accepts it as possibly true but "too simplistic".