## Facts

- Alan’s of Atlanta, Inc. operated specialty camera stores in Georgia and Florida and was a major retailer of Minolta products in the Atlanta market.
- In 1979, Alan’s had roughly 33% of Atlanta Minolta camera sales and about 78% of Minolta sales through specialty camera stores.
- By 1985, Alan’s share of Atlanta Minolta sales fell to about 4%, with a similar decline in specialty-store Minolta sales.
- Over the same period, Wolf Camera’s Minolta share in Atlanta increased from about 6% to about 41%, and its specialty-store share rose from about 14% to over 65%.
- Alan’s alleged Minolta operated a “key dealer” program that favored Wolf by providing free cameras, advertising, and other promotional benefits not offered to Alan’s on proportionally equal terms, and by providing Wolf more favorable net prices or terms.
- Alan’s asserted Robinson-Patman Act claims under §§ 2(a), 2(d), 2(e), and (as to Wolf) 2(f), alleging the discriminatory pricing and promotional allowances diverted sales and caused loss of market share and profits.
- The district court granted summary judgment to defendants, concluding Alan’s failed to show antitrust injury and that no genuine issues of material fact existed.

## Issues

1. Whether Alan’s presented sufficient evidence of antitrust injury and causation to have standing to pursue Robinson-Patman Act claims.
2. Whether genuine disputes of material fact regarding discriminatory pricing/promotional practices and competitive injury made summary judgment improper.

## Decision

- The Eleventh Circuit reversed the grant of summary judgment and remanded.
- The court held the record permitted a reasonable jury to find price discrimination and discriminatory promotional allowances under Robinson-Patman Act §§ 2(a), 2(d), 2(e), and 2(f).
- The court held Alan’s produced sufficient evidence for a jury to infer antitrust injury and causation, given the alleged preferential benefits to Wolf and the marked shift in competitive outcomes.
- The court ruled the district court improperly resolved contested causal explanations (discrimination versus internal business problems) at the summary-judgment stage.

## Legal Principles

- A private Robinson-Patman plaintiff must show antitrust injury: harm of the type the antitrust laws address, and a causal connection between the challenged conduct and the plaintiff’s injury.
- In Robinson-Patman cases, competitive injury may be inferred where a seller’s discriminatory prices or promotional benefits give one competing buyer a meaningful advantage and there is evidence of resulting sales diversion or altered competitive conditions.
- On summary judgment, courts must draw reasonable inferences in favor of the nonmovant and may not weigh evidence or choose between competing explanations where material facts are disputed.
- Disputed questions about whether discriminatory allowances/pricing occurred, whether they were available on proportionally equal terms, and whether they materially contributed to market-share shifts are generally for the factfinder when supported by record evidence.

## Conclusion

The Eleventh Circuit concluded that evidence of a preferred-dealer program, unequal promotional benefits, and sharply divergent market-share trends created triable issues on Robinson-Patman violations and antitrust injury, requiring reversal of summary judgment and remand for further proceedings.


Alan’s of Atlanta, Inc. v. Minolta Corp., 903 F.2d 1414 (11th Cir. 1990)