Duty Free Americas, Inc. v. The Estee Lauder Co.

DFA filed suit against Estee Lauder after Estee Lauder refused to do business with DFA and communicated that fact to airport authorities evaluating whether to offer rental space to DFA. DFW alleged three claims in its amended complaint: (1) attempted monopolization, in violation of section 2 of the Sherman Act, 15 U.S.C. 2; (2) contributory false advertising, in violation of section 43(a) of the Lanham Act, 15 U.S.C. 1125(a); and (3) tortious interference with a prospective business relationship, in violation of Florida law. The district court dismissed the suit based on failure to state a claim. The court concluded that DFW failed to allege basic facts sufficient to state a claim to relief that is plausible on its face where DFW did not adequately allege that Estee Lauder engaged in predatory or anticompetitive conduct for its antitrust claims; DFA does not come close to establishing standing to seek injunctive relief from the requirements that Estée Lauder places on its competitors, inasmuch as DFA no longer does any business with Estée Lauder; DFA failed to plead sufficient facts from which a court could find that Estée Lauder made false statements, or, for that matter, was responsible for any such statements made by DFA’s competitors in DFA's false advertising claim; and the complaint failed to allege any improper conduct sufficient to constitute tortious interference with a business relationship in violation of Florida law. Accordingly, the court affirmed the judgment. View "Duty Free Americas, Inc. v. The Estee Lauder Co." on Justia Law