In AD/SAT, Div. Of Skylight, Inc. v. Associated Press, the plaintiff specialized in delivering electronic advertising to newspapers nationwide from the mid-1980s until 1996. The defendant association began competing against the plaintiff. Plaintiff’s cause failed for lack of sufficient evidence to show tangible harm, material fact, and the evidence the plaintiff presented was inadequate to withstand the level of scrutiny required by the United States Supreme Court in an antitrust suit.

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