Snow v. Align Technology, Inc.
- Vince Chhabria
- 3:21-cv-03269
- U.S. District Court · Northern District of California
- 1
In Snow v. Align Technology, Inc., Judge Chhabria denied Align’s motion to join SmileDirectClub, finding the antitrust claim seeks damages only.
Align Technology’s motion to add SmileDirectClub as a necessary party was denied; SmileDirectClub may still seek to intervene.
What happened
In Snow v. Align Technology, Inc., Align Technology asked the court to add SmileDirectClub as a required party in the plaintiffs’ antitrust lawsuit.
The plaintiffs said they were not seeking an injunction under their Section 1 claim, which the court understood as seeking damages only. Align argued that agreements involving SmileDirectClub made it necessary to include SmileDirectClub in the case.
Judge Chhabria denied Align’s motion. He said requiring SmileDirectClub to be added, when no injunction was possible on that claim, would conflict with the general rule that plaintiffs do not have to sue every alleged antitrust conspirator. SmileDirectClub may still ask to join the case.
The detailed version
- Snow v. Align Technology, Inc. · No. 3:21-cv-03269
- Vince Chhabria
- Aug. 26, 2022
Background
The plaintiffs brought an antitrust claim under Section 1. Align Technology moved to join SmileDirectClub as a necessary party, meaning a party that Align argued had to be included for the case to proceed.
Court’s Analysis
The court stated that the plaintiffs were clear they were not seeking injunctive relief on the Section 1 claim. Although the complaint could have been drafted more carefully, the court found that the fairest reading was that the claim sought damages only.
The court rejected Align’s argument that agreements involving SmileDirectClub made SmileDirectClub a necessary party. Without the possibility of an injunction on that claim, accepting Align’s argument would undermine the general rule that a plaintiff does not have to sue every alleged antitrust conspirator. The court cited Ward v. Apple, Inc., 791 F.3d 1041, 1052 (9th Cir. 2015).
Disposition
Judge Vince Chhabria denied Align’s motion to join SmileDirectClub. The court also stated that SmileDirectClub remained free to move to intervene, meaning to ask to participate in the case voluntarily.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.