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Violations of Section 2 of the Sherman Act often involve refusals to deal with rivals. The refusals may be primary, if the dominant firm denies its rivals access to a needed resource that it controls. Or the refusals may be secondary, if the dominant firm threatens to refuse to deal with upstream or downstream firms that deal with its rivals. The goal of any of these refusals to deal, if they are inefficiently exclusionary, is to destroy the rival or to limit its ability to compete by preventing it from contracting with vendors or outlets on beneficial terms. If successful, the harm to the rival may harm competition by preserving the defendant's monopoly power. Where a dominant firm's refusal to deal demonstrably reduces competition, courts may order the firm to contract or at least offer to contract. The American and European Microsoft cases resulted in several versions of this kind of remedy.