Source: cases/15usc1/f-supp-3d-386-926-maui-jim-v-smartbuy-guru.case
Case source: https://www.neochart.com/catalog/cases/f-supp-3d/volume_386/0926_01/index.html
SBG's antitrust claim therefore does not allege antitrust injury because, as a "direct competitor of Maui Jim," Maui Jim's alleged contracts resulted in "artificially high prices for Maui Jim sunglasses."
SBG's failure to plead a plausible relevant market renders dismissal appropriate.
casedsl 1.2
# author: Flash1 (gemini-3.8-flash-high)
# triaged-by: Fable (2026-11-10)
case /f-supp-3d/386/0926-01
name Maui Jim, Inc. v. Smartbuy Guru Enters.
cite 386 F. Supp. 3d 926 (2019)
# IR court field says: United States District Court for the Eastern District of Illinois
court United States District Court for the Northern District of Illinois
date 2019-05-10
url catalog/cases/f-supp-3d/volume_386/0926_01/index.html
source ir/caselaw/f_supp_3d_386.jsonl sha1=a181a2f3f541789e5a740c65c5ea252f2ea83ab0 chars=60000
opinion op : order by Aspen @0..60000 controlling
? opinion: the IR text is capped at 60000 chars; the cut falls in Part V (EU antitrust counterclaim, forum non conveniens). Part III, the Sherman Act counterclaim (@27859..40612), is complete. The ruling striking the "inequitable restraint of trade" affirmative defense lies beyond the cap.
party sbg : SmartBuy Guru Enterprises and affiliates (unauthorized online discount reseller; defendants and counterclaimants - the § 1 claimant)
party maui-jim : Maui Jim, Inc. (sunglasses manufacturer; plaintiff and counterclaim defendant)
theory rpm : Count III counterclaim: Maui Jim's contracts with authorized distributors set minimum retail prices, restrict resale, and cut off retailers that supply SBG
law 15usc1
role applied
posture civil trademark suit by manufacturer against unauthorized online reseller; reseller's § 1 counterclaim (Count III) attacks the manufacturer's distributor contracts; manufacturer's Rule 12(b)(6) motion granted with prejudice for want of antitrust injury and of a plausible relevant market
result claimant-lost
element injury : not-satisfied [pleaded]
party sbg maui-jim
theory rpm
route antitrust-injury
pattern self-described direct competitor complaining of the rival's artificially high resale prices and of losing its supply
rule @30122..30424 [quoted] | "A competitor may not 'recover damages for any conspiracy ... to charge higher than competitive prices," because although "[s]uch conduct would indeed violate the Sherman Act," it cannot injure a claimant competitor because competitors " 'stand to gain from any conspiracy to raise the market price.' "
fact @30829..30900 [cuts-against] | SBG squarely characterizes itself as a "direct competitor of Maui Jim."
fact @31681..31826 [supports] | SBG nevertheless alleges it was harmed "because Maui Jim has unlawfully restricted and seeks to eliminate [SBG's] supply of Maui Jim sunglasses."
fact @5681..5804 [supports] | Maui Jim has allegedly threatened to terminate and has actually terminated retailers that have sold authentic goods to SBG.
held @31106..31310 | SBG's antitrust claim therefore does not allege antitrust injury because, as a "direct competitor of Maui Jim," Maui Jim's alleged contracts resulted in "artificially high prices for Maui Jim sunglasses."
gloss The court holds the claimant to its own pleading label ("direct competitor") and treats the supply-cut-off theory as inconsistent with it and unsupported by authority (waived as undeveloped).
? other: SBG is a reseller of Maui Jim product, not a rival manufacturer; the court's competitor-benefits-from-high-prices reasoning rests on SBG's own characterization, not on an analysis of the market level.
element restraint.rule-of-reason : not-satisfied [pleaded]
party sbg maui-jim
theory rpm
route market-definition
pattern single-brand market (one manufacturer's sunglasses) pleaded by a retailer that itself sells 180 competing brands
rule @34130..34428 [quoted] | "When a complaint limits the relevant market to a 'single brand, franchise, institution, or comparable entity that competes with potential substitutes,' a court should dismiss the complaint unless the complaint contains sufficient factual allegations that make it plausible there is no substitute."
fact @33101..33319 [supports] | SBG identifies the alleged relevant antitrust market as the "Maui Jim sunglasses market, specifically Maui Jim sunglasses that are marketed and sold throughout the United States either online or through retail stores."
fact @38976..39153 [supports] | SBG's only other allegation that Maui Jim sunglasses constitute a market unto themselves states, "Maui Jim's products are differentiated by virtue of their labeling and design."
fact @36028..36115 [cuts-against absent] | SBG's minimal allegations say nothing regarding cross-elasticities of supply or demand.
fact @38000..38222 [cuts-against] | The asserted single-brand market in Maui Jim sunglasses is all the more implausible in light of SBG's allegation that it sells "products from more than 180 of the world's best-selling designer brands at attractive prices."
held @38472..38553 | SBG's failure to plead a plausible relevant market renders dismissal appropriate.
gloss The opinion does not name the mode of analysis; it requires a relevant market as part of the second § 1 element for these vertical resale restraints.
? other: no explicit choice of the rule of reason appears in the text; the block sits on restraint.rule-of-reason because the ruling is the relevant-market requirement of that mode.
element agreement : not-reached
party sbg maui-jim
gloss Maui Jim "does not take issue with the first element" on this motion (@28811); the court makes no ruling on it.