Illinois Tool Works Inc. v. Independent Ink, Inc.

Summary

The Court held that a patent on a tying product does not by itself establish market power for purposes of a tying claim under the Sherman Act. A plaintiff challenging a tying arrangement must prove that the defendant possesses market power in the tying-product market, rather than rely on a presumption arising solely from the patent. The Court vacated the judgment and remanded to allow the plaintiff an opportunity to develop evidence of market definition and market power.