The Federal Trade Commission (FTC) filed suit against the California Dental Association (CDA). The CDA also had member services that allowed members to increase profits, such as insurance discounts and other economic benefits. The FTC brought its complaint against the CTA on the grounds that the CDA’s restrictions on its members advertising went too far and actually restricted truthful, nondeceptive advertising, which lead to anticompetitive effects. The US Supreme Court adopted an intermediate test, which lies between the per se anticompetitive illegality test and the standard rule-of-reason test. The Supreme Court also stated that the quick-look rule-of-reason analysis did not necessarily have to be supported with a detailed market analysis and stated that there were no bright lines between per se analysis, quick-look analysis, or full rule-of-reason analysis.

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