Chroma Lighting v. GTE Products Corp.

Plaintiff Charles Von Der Ahe, d/b/a Chroma Lighting, was a distributor of Osram Sylvania lighting products. After going out of business, Von Der Ahe sued Sylvania for price discrimination in violation of § 2(a) of the Clayton Act, as amended by the Robinson-Patman Antidiscrimination Act of 1936, 15 U.S.C. § 13 (a), and for recovery under California tort law. On the Robinson-Pat-man claim, Von Der Ahe alleged that Sylva-nia had given discounts to Von Der Ahe’s larger competitors, without offering the same discounts to Von Der Ahe, and that Von Der Ahe had been injured by Sylvania’s discriminatory practices. The jury found for Von Der Ahe on all counts and awarded treble damages of $3,525,000. ER at 719-20. After trial, Sylvania moved for judgment as a matter of law, alleging, inter alia, that there was insufficient evidence to support a finding of injury to competition on the Robinson-Patman claim. ER at 438^40. The district court denied the motion. Sylvania appeals from the denial of its post-trial motion and from the judgment. On appeal, Sylvania claims that the evidence at trial was insufficient as a matter of law to support the jury’s finding of injury to competition.

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