context: Although this inquiry may overlap with the separate-products screen under the per se rule, that is not its role here. Because courts applying the rule of reason are free to look at both direct and indirect evidence of efficiencies from a tie, there is no need for a screening device as such; thus the separate-products' inquiry serves merely to classify arrangements as subject to tying law, as opposed to, say, liability for exclusive dealing.
citation_a.signal: see also
citation_a.identifier: 75 F.Supp.2d 626, 635, 643-44
citation_a.parenthetical: considering a rule of reason tying claim, after finding a single product under the per se rule
citation_a.sentence: See Times-Picayune, 345 U.S. at 614, 73 S.Ct. 872 (finding a single product and then turning to a general rule of reason analysis under § 1, though not using the term “tying”); Foster v. Md. State Sav. & Loan Ass’n, 590 F.2d 928/931, 933 (D.C.Cir.1978), cited in Jefferson Parish, 466 U.S. at 40, 104 S.Ct. 1551 (O’Connor, J., concurring) (same); see also Chawla v. Shell Oil Co., 75 F.Supp.2d 626, 635, 643-44 (S.D.Tex. 1999) (considering a rule of reason tying claim, after finding a single product under the per se rule); Montgomery County Ass’n of Realtors v. Realty Photo Master Corp., 783 F.Supp. 952, 961 & n. 26 (D.Md.1992), aff'd mem. 993 F.2d 1538 (4th Cir.1993) (same).
citation_b.signal: see
citation_b.parenthetical: finding a single product and then turning to a general rule of reason analysis under SS 1, though not using the term "tying"
citation_b.sentence: See Times-Picayune, 345 U.S. at 614, 73 S.Ct. 872 (finding a single product and then turning to a general rule of reason analysis under § 1, though not using the term “tying”); Foster v. Md. State Sav. & Loan Ass’n, 590 F.2d 928/931, 933 (D.C.Cir.1978), cited in Jefferson Parish, 466 U.S. at 40, 104 S.Ct. 1551 (O’Connor, J., concurring) (same); see also Chawla v. Shell Oil Co., 75 F.Supp.2d 626, 635, 643-44 (S.D.Tex. 1999) (considering a rule of reason tying claim, after finding a single product under the per se rule); Montgomery County Ass’n of Realtors v. Realty Photo Master Corp., 783 F.Supp. 952, 961 & n. 26 (D.Md.1992), aff'd mem. 993 F.2d 1538 (4th Cir.1993) (same).