Implications Of Starr V. BMG Music

Law360, New York (February 18, 2010, 4:38 PM EST) -- Last month, the Second Circuit reversed the Southern District of New York’s dismissal of a complaint on Twombly grounds, finding that a variety of allegations, when combined, supported the inference of a conspiracy. Starr v. Sony BMG Music Entm’t, No. 08-5637-cv, 2010 WL 99346 (2d Cir. Jan. 13, 2010).

The Starr case involved a purported conspiracy among competitors selling music online (“digital music”) to fix prices via joint ventures and a trade association.

The court found that a grand total of seven plus factors were alleged...
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