In re Interior Molded Doors Antitrust Litig.
United States District Court for the Eastern District of Virginia, Richmond Division
September 18, 2019, Decided; September 18, 2019, Filed
Lead Civil Action No. 3:18-cv-00718-JAG; Lead Civil Action No. 3:18-cv-00850-JAG
In these consolidated class actions, two groups of plaintiffs contend that America's leading manufacturers of interior molded doors unlawfully conspired to fix prices. The first group of plaintiffs—the direct purchaser plaintiffs—bought interior molded doors directly from the defendants, Masonite Corporation and JELD-WEN, Inc. The direct purchaser plaintiffs seek damages under the Sherman Act for the defendants' alleged anticompetitive conduct. The second group of plaintiffs—the indirect purchaser plaintiffs—bought interior molded doors indirectly from the defendants through distributors. The indirect purchaser plaintiffs seek injunctive relief under the Sherman Act and damages under the laws of thirty-nine states. The defendants have moved [*7] to dismiss both complaints for failure to state a claim.
Because the direct and indirect purchaser plaintiffs sufficiently allege that the defendants conspired to fix prices, the Court will deny the motion to dismiss for failure to state a claim as to the Sherman Act. Some of the indirect purchaser plaintiffs' claims arising under state law, however, fall short in various respects. Accordingly, the Court will grant in part the motions to dismiss. In this Opinion, the Court will address each claim in turn.
I. FACTS ALLEGED IN THE COMPLAINTS
Most American homes contain interior molded doors ("IMDs"), which separate interior rooms, hallways, and closets. Manufacturers produce IMDs "by sandwiching a wood frame and a hollow or solid core between two doorskins composed of a high-density fibrous mat and formed into a raised panel design." (Dk. No. 119, 3:18-cv-718, at ¶ 1.) Doorskins comprise the most important part of IMDs, representing up to 70 percent of the overall cost of IMDs.
JELD-WEN and Masonite are the two largest manufacturers of IMDs in the United States. In 2012, JELD-WEN acquired another manufacturer of IMDs and doorskins, CraftMaster International, Inc. ("CMI"). After the acquisition, [*8] JELD-WEN and Masonite became the only two manufacturers of doorskins in the United States and controlled 85 percent of the national IMD market. Because the manufacturers comprising the other 15 percent of the IMD market did not make doorskins, they had to buy doorskins from the defendants, who had aggressively competed for the business of those manufacturers in the past. In 2014, Masonite abruptly stopped selling doorskins to third parties, making JELD-WEN the sole supplier of the largest component of IMDs.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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2019 U.S. Dist. LEXIS 161045 *; 2019-2 Trade Cas. (CCH) P80,961; 2019 WL 4478734
IN RE: INTERIOR MOLDED DOORS ANTITRUST LITIGATION;IN RE: INTERIOR MOLDED DOORS INDIRECT PURCHASER ANTITRUST LITIGATION
Prior History: In re Interior Molded Doors Antitrust Litig., 2019 U.S. Dist. LEXIS 36167 (E.D. Va., Mar. 6, 2019)
antitrust, consumer, indirect, unjust, conspiracy, enrichment, deceptive, unfair, doorskins, manufacturers, notice, fraudulent, remoteness, diligence, conspired, door, bought, indirectly, input, concealment, standalone, interior, anticompetitive, interchangeable, unconscionable, injunctive, prong, circumstantial, certification, concentrated