In Massachusetts School of Law at Andover, Inc. v. American Bar Ass’n (1997 WL 136240 (D.Mass 1997)), the plaintiff law school sued the defendant for failure to approve accreditation for the plaintiff. The action rested on an antitrust theory. The court disagreed, noting that cooperation between organizations like the defendants and others served a valuable service in society. The court refused to infer conspiracy or complicity where the actions of the associations performed such a service. The court also noted that just because two associations work together, it does not give grounds to either antitrust or conspiracy charges.

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