State v. Densmore Brick Co
In State v. Densmore Brick Co., 1980 WL 1846, at 1 (D.Vt. Apr. 10, 1980), the State of Vermont sued a woodburning stove distributor for violations of the Sherman Act and the VCFA.
In ruling on defendant's summary judgment motion, the court stated the general rule of Illinois Brick: that an antitrust plaintiff who was not a direct purchaser could not recover.
However, in denying the motion, the court ultimately found no reason to apply the indirect purchaser rule, as plaintiff had alleged a direct relationship. Id.