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Abstract

Professor Ponsoldt argues that courts may treat sellers or combinations of sellers of products or services under section 2 of the Sherman Act differently after Eastman Kodak Co. v. Image Technical Services, when consumers are locked into certain secondary markets or after-markets by virtue of an original purchasing decision and where the cost or practical availability of switching to an alternative primary product eliminates price or service sensitivity. He reviews three "actual" cases in the health care context: Case A involves a "non-immunized" revocation of hospital staff privileges; Case B involves a denial of hospital privileges to competing, differentially credentialed, state licensed providers; and Case C involves the closure of membership in a comprehensive health care plan, specifically a preferred provider organization ("PPO") with apparently anticompetitive restrictions.

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