Indirect purchasers who bought through intermediaries cannot recover federal antitrust damages. The rule avoids duplicative recovery and complex pass-through calculations, and many states permit indirect purchaser claims under state law.
Apple v. Pepper clarified direct purchaser status in platform contexts.
Alternative Names:
Illinois Brick|Direct Purchaser Rule
Why it Matters?
State repealer statutes permitting indirect purchaser claims mean the federal bar does not eliminate exposure, since parallel state class actions proceed on behalf of downstream purchasers in the majority of states. That structure produces coordinated federal direct purchaser and state indirect purchaser litigation over the same conduct. Apple v. Pepper also treated platform purchasers as direct purchasers, expanding federal standing in digital contexts.
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Frequently asked questions
Does the doctrine eliminate exposure?
What did Apple v. Pepper establish?
