Minn-Chem, Inc., et al. v. Agrium Inc., et al., 657 F.3d 650 (7th Cir. 2011)

(multi-district antitrust class action alleged global conspiracy to raise price of potash; class alleged Canadian, Russian, and Belarusian producers operated cartel to fix potash prices in Brazil, China, and India, and inflated prices, influencing price of potash sold in U.S.; district court denied defendant’s motion to dismiss; on appeal, defendants argued that district court lacked subject-matter jurisdiction under Foreign Trade Antitrust Improvements Act (FTAIA) and complaint did not satisfy pleading requirements; appellate court reversed, holding that FTAIA limits extraterritorial reach of Sherman Antitrust Act to foreign anticompetitive conduct that either involves U.S. import commerce or has effect on U.S. import or domestic commerce and FTAIA’s limitations are jurisdictional).

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