International Salt Co. v. United States, 332 U.S. 392

Case citation

Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...

 (1947), was a case in which the United States Supreme Court

Supreme Court of the United States

The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...

 held that the Sherman Act prohibits as per se

Illegal per se

The term illegal per se means that the act is inherently illegal. Thus, an act is illegal without extrinsic proof of any surrounding circumstances such as lack of scienter or other defenses...

violations all tying arrangements in which a product for which a seller has a legal monopoly

Monopoly

A monopoly exists when a specific person or enterprise is the only supplier of a particular commodity...

, such as a patent

Patent

A patent is a form of intellectual property. It consists of a set of exclusive rights granted by a sovereign state to an inventor or their assignee for a limited period of time in exchange for the public disclosure of an invention....

, requires purchasers to also buy a product for which the seller has no legal monopoly.

Facts

The defendant

Defendant

A defendant or defender is any party who is required to answer the complaint of a plaintiff or pursuer in a civil lawsuit before a court, or any party who has been formally charged or accused of violating a criminal statute...

 International Salt Company had patented machines for processing salt

Salt

In chemistry, salts are ionic compounds that result from the neutralization reaction of an acid and a base. They are composed of cations and anions so that the product is electrically neutral...

and mixing or injecting it into various foodstuffs. The company required those who leased machines to also buy the salt or salt tablets processed through the machines from the defendant. The United States government brought a case charging the company of an antitrust violation through the tying of its products. The defendant replied to the charges with the contention that the tying arrangement was necessary to control the quality of salt being used in its machines, claiming that salt not meeting certain standards would damage the machines.

Issue

The Supreme Court was asked to determine whether such an arrangement was a per se violation of the antitrust laws.

Opinion of the Court

The Court held that this was a per se violation, announcing that it would be no defense to say that the associated product must meet certain standards because competitors must be given the opportunity to meet them. It was also no defense to say that customers could buy elsewhere if other vendors sold at lower prices, as the defendant could foreclose the market simply by meeting it.