TWENTY-ONE YEARS OF ANTITRUST INJURY: DOWN THE ALLEY WITH BRUNSWICK v. PUEBLO BOWL-O-MAT

Has the plaintiff suffered "antitrust injury?" That is a question no one asked until twenty-one years ago, when the Supreme Court decided Brunswick Corp. v. Pueblo Bowl-O-Mat, Inc.1 Today the question arises in every private antitrust case, and is typically one of the most fierce battlegrounds in all but the most straightforward horizontal price-fixing disputes. In virtually every private merger action,2 vertical restraint case,3 and competitor suit of any kind,4 antitrust injury is a critical issue.