Rule of Reason Analysis Factors
In C.K. & J.K., Inc, the Ohio Supreme Court cited Standard Oil Co. v. United States (1911), 221 U.S. 1, 31 S.Ct. 502, 55 L.Ed. 619,
In Standard Oil Co. v. United States (1911), 221 U.S. 1, 31 S.Ct. 502, 55 L.Ed. 619, the United States Supreme Court, construing the Sherman Act, stated that "'the criteria to be resorted to in any given case for the purpose of ascertaining whether violations have been committed, is the rule of reason guided by the established law and by the plain duty to enforce the prohibitions of the act and thus the public policy which its restrictions were obviously enacted to subserve." Id., citing Standard Oil Co., supra.
Federal courts have stated that a rule of reason analysis requires the plaintiff to prove all of the following:
"(1) that the defendant(s) contracted, combined, or conspired;
(2) that such contract produced adverse anticompetitive effects;
(3) within the relevant product and geographic markets;
(4) that the objects of and conduct resulting from the contract were illegal;
(5) that the contract was a proximate cause of plaintiff's antitrust injury." Care Heating & Cooling, Inc. v. American Standard, Inc. (C.A. 6, 2005), 427 F.3d. 1008, 1014, citing Int'l Logistics Group, Ltd. v. Chrysler Corp., 884 F.2d 904, 907 (6th Cir.1989).