Source: cases/15usc1/f-supp-3d-386-1308-jain-irrigation-v-netafim.case
Case source: https://www.neochart.com/catalog/cases/f-supp-3d/volume_386/1308_01/index.html
Moreover, the law is clear that vertical agreements involving boycotts must be analyzed under the rule of reason.
The conspiracy alleged by plaintiff in the FAC simply is not susceptible to per se treatment under controlling law, because of which it must be dismissed.
casedsl 1.2
# author: Flash1 (gemini-3.8-flash-high)
# triaged-by: Fable (2026-11-10)
case /f-supp-3d/386/1308-01
name Jain Irrigation, Inc. v. Netafim Irrigation, Inc.
cite 386 F. Supp. 3d 1308 (2019)
court United States District Court for the Eastern District of California
date 2019-05-13
url catalog/cases/f-supp-3d/volume_386/1308_01/index.html
source ir/caselaw/f_supp_3d_386.jsonl sha1=aaa16c3cee5e7230aa61a81851abab145f1afdc2 chars=23830
opinion op : order by Drozd @0..23830 controlling
party plaintiffs : Jain Irrigation, Inc. (manufacturer) and its part-owned distributors Agri-Valley Irrigation (AVI) and Irrigation Design & Construction (IDC) (plaintiffs)
party netafim : Netafim Irrigation, Inc. (competing manufacturer, alleged instigator; sole defendant)
theory boycott : a single conspiracy in which rival manufacturers cut off AVI and IDC and, in exchange, distributors reduced or ended purchases from Jain; pleaded exclusively as a per se violation
law 15usc1
role applied
posture civil; irrigation manufacturer and two affiliated distributors sued a rival manufacturer under § 1 and the Cartwright Act for a boycott pleaded exclusively as per se unlawful; Rule 12(b)(6) motion granted with leave to amend
result claimant-lost
element restraint.per-se : not-satisfied [pleaded]
party plaintiffs netafim
theory boycott
route boycott-or-exclusion
pattern single conspiracy mixing manufacturer-level and manufacturer-distributor refusals to deal, pleaded only as per se
rule @19298..19411 | Moreover, the law is clear that vertical agreements involving boycotts must be analyzed under the rule of reason.
fact @2196..2425 [supports] | In furtherance of the conspiracy, each of these companies (collectively, the "Conspiring Manufacturers") terminated their prior business relationships with IDC and AVI and refused to supply any further products to either company.
fact @2441..2794 [cuts-against] | That same month, and pursuant to the same conspiracy, the Conspiring Manufacturers agreed with an unknown number of distributors (including at least Landmark and Hydratec) that in exchange for the Conspiring Manufacturers' agreement to boycott AVI and IDC, the distributors would boycott Jain by reducing or terminating their purchases of Jain products.
fact @5587..5731 [supports] | At the meeting, the distributors discussed strategies to "take out" AVI and IDC and agreed that they should work together to damage AVI and IDC.
fact @19020..19137 [cuts-against] | This argument is belied by the FAC itself and the allegations therein which repeatedly refers to a single conspiracy.
held @20113..20267 | The conspiracy alleged by plaintiff in the FAC simply is not susceptible to per se treatment under controlling law, because of which it must be dismissed.
gloss Plaintiffs disclaimed the rule of reason (FAC ¶ 6 n.1), so rejection of per se treatment disposed of the complaint. The court acknowledged the pleaded structure includes horizontal agreements among manufacturers but refused to split the single pleaded conspiracy into separate horizontal ones.
? basis: [pleaded] because the ruling takes the FAC's allegations as true; it is equally a ruling of law on the mode of analysis ("even if proven").
element restraint.rule-of-reason : not-reached
party plaintiffs netafim