Last week, on April 8, 2014, the District Court for the Eastern
District of Michigan dismissed the remaining claims of indirect
purchaser plaintiffs (IPPs) in the ongoing Refrigerant Compressors
litigation. In re: Refrigerant Compressors, Case No.
2:09-md-02042 (E.D. Mich. April 8, 2014). Almost exactly one
year ago, the court dismissed most of the IPPs' claims, mainly
on the basis that the IPPs lacked antitrust standing to bring them.
In re: Refrigerant Compressors, Case No.
2:09-md-02042, Doc. 343 (E.D. Mich. April 9, 2013). As
a result of that decision, the IPPs' case was limited to claims
based ononly two state statutes seeking damages against
manufacturers of fractional compressors used in refrigeration
devices, based on sales that occurred in only those two states.
The court's decision dismissing the last two state claims
was brief and resulted from a stipulation among the IPPs and those
particular manufacturers to dismiss the claims. The parties
have not
