Antitrust class action cases continue to face the ripple effects of Bell Atlantic Corp. v. Twombly (550 U.S. 544 (2007)), which requires plaintiffs to plead facts that support a plausible theory of liability. Meanwhile, a forthcoming decision in American Needle v. NFL (538 F.3d 736 (7th Cir.), cert granted, 129 S.Ct. 2859 (2009)), could affect when business decisions of joint ventures are considered anti-competitive.
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