In Allied Tube & Conduit Corp. v. Indian Head, Inc., 486 U.S. 492, 495-97, 108 S.Ct. 1931, 100 L.Ed.2d 497 (1988), the Court imposed antitrust liability on the defendant, a manufacturer of steel electrical conduits. This liability was for predatory actions undertaken to coerce the National Fire Protection Association ("NFPA"), a body that published product standards and building codes, to publish standards barring the use of plastic conduits, a rival product which the plaintiff manufactured. The activities undertaken by the defendant in Allied Tube included such conduct as packing NFPA meetings with paid supporters of the defendant who would advocate for the banning of plastic pipes. Id. at 496, 108 S.Ct. 1931. The Court noted that even such "unethical and deceptive practices" are protected from antitrust liability where they are either directly aimed at or "`incidental' to a valid effort to influence government action." Id. at 499, 108 S.Ct. 1931. However, the Court explained that predatory activities aimed at private standards-setting bodies, like NFPA, do not enjoy such categorical protection from liability. The Court pointed to the "procompetitive advantages" of private standards-setting organizations whose decisions are insulated from "being biased by members with interests in stifling product competition." Id. at 501, 108 S.Ct. 1931. In concluding that the defendant's predatory activities subjected it to liability, the Court emphasized the fact that the NFPA, the body the defendant sought to coerce, was a private organization without any accountability to the public. Id. at 502, 108 S.Ct. 1931.