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Antitrust and Trade Regulation

University of Richmond Law Review

1999

Commercial Business Systems Inc. v. BellSouth Services Inc.

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Annual Survey Of Virginia Law: Antitrust And Trade Regulation, Michael F. Urbanski, James R. Creekmore Jan 1999

Annual Survey Of Virginia Law: Antitrust And Trade Regulation, Michael F. Urbanski, James R. Creekmore

University of Richmond Law Review

During the past year, the United States Supreme Court, in two decisions of significance, refused to summarily censure conduct having legitimate, procompetitive benefits. In similar fashion, the United States Court ofAppeals for the Fourth Circuit continued to scrutinize antitrust claims, rejecting those failing to measure up to pleading and proof requirements, while also reaffirming the vitality of the state action immunity doctrine as a bar to those that did. Meanwhile, Virginia's federal district courts grappled with time worn conspiracy challenges to medical staff privileging decisions, while simultaneously forging new ground in one of the first cases to consider market definition …