In Jefferson County School Dist. No. R-1 v. Moody’s Investors Services, Inc., (175 F.3d 848 (10th Cir. 1999)), the plaintiff brought an antitrust action in addition to defamation and breach of contract grounds. The defendant had published an unfavorable credit report after the plaintiff had issued a series of bonds. The antitrust theory relied upon the idea that the defendant’s reports would cast a shadow over the credit companies working with the school district on the bond project. The court held that the defendant had merely expressed an opinion as to the plaintiff, and was in no way in violation of an antitrust law.

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