## Facts

- The United States sued a hardwood-flooring trade association, its corporate members, and representatives under § 1 of the Sherman Act, seeking an injunction and dissolution.
- Member firms manufactured and sold maple, beech, and birch flooring in interstate commerce; the government alleged members accounted for a large share of production.
- The association collected and distributed aggregated industry information, including average production costs derived from member reports and testing directed by the association’s secretary.
- The association compiled freight-rate materials to allow members to calculate delivered prices from basing points to destination points.
- Members reported detailed data on completed sales (quantities, dates, prices) and other business conditions (stock on hand, unfilled orders, production, and new orders), which the secretary returned in summarized form.
- The distributed information concerned past transactions, omitted current price quotations and many transaction-specific details, and did not identify individual members or purchasers.
- The government relied in part on evidence of prior industry combinations, arguing the association continued an anticompetitive course.
- The district court granted relief for the government and ordered dissolution; defendants appealed.

## Issues

1. Whether a trade association’s open collection and dissemination of aggregated cost, freight, and past sales statistics among competitors violates Sherman Act § 1 absent proof of an agreement to fix prices, restrict output, or otherwise restrain competition.
2. Whether a conspiracy or unlawful restraint may be inferred solely from statistical reporting and discussion practices in an industry trade association.

## Decision

- The Supreme Court reversed the decree and denied injunctive relief.
- The Court held the association’s practices, on this record, did not constitute an unlawful restraint of trade under Sherman Act § 1.
- The Court found no evidence of a present agreement or concerted plan to fix prices, limit production, or coerce uniform conduct through the association.
- Prior cases condemning information exchanges were distinguished because they involved concerted action or mechanisms effectively coordinating pricing or output.

## Legal Principles

- Sherman Act § 1 liability turns on the facts shown; similar practices may be lawful or unlawful depending on their purpose, operation, and competitive effects.
- Open and fair dissemination of aggregated information about costs, past prices, inventories, and transportation costs, coupled with meetings to discuss such information, is not unlawful without an agreement or concerted action concerning prices, production, or restraint of competition.
- A tendency of information sharing to make competition more informed or to stabilize prices incidentally does not, by itself, establish the “direct and undue” restraint condemned by § 1.
- A conspiracy to restrain trade will not be inferred from statistical reporting alone where the data concern past transactions, omit identifying details, and are not used as a vehicle to reach or enforce price or output agreements.

## Conclusion

Because the record showed only an open program of collecting and distributing aggregated historical industry statistics, without proof that the association was used to reach or enforce agreements on price or output, the Court concluded there was no Sherman Act § 1 violation and reversed the order dissolving the association.


Maple Flooring Mfrs.' Ass'n v. United States, 268 U.S. 563 (1925)