Alaska Airlines v. United Airlines

Citation
Alaska Airlines v. United Airlines, 948 F.2d 536 (9th Cir. 1991), cert. denied, 503 U.S. 977 (1992).

Factual Background
The defendants were airline owners of proprietary computer reservation systems. The plaintiffs claimed that the defendants had violated Section 2 of the Sherman Act by denying competitors reasonable access to an "essential facility" by charging airlines $1.75 per booking.

Appellate Court Proceedings
The court rejected the Section 2 claim on the ground that the defendants lacked the power to eliminate competition in the downstream air transportation market. The court indicated that standards for assessing access denial under Section 2 are more stringent than those required under Section 1 of the Sherman Act.