Dexian Corp.v.Sony Corp.:from Requirement of Tying to Relationship of Markets

With regard to Dexian Co. v. Sony Co., we cannot take it for granted that Sony is conducting illegal tying. As a matter of fact, Sony hasn’t dominant position in equipment market of digital camera, and doesn’t satisfy the requirement of single-product in respect of tying. Therefore it does not constitute illegal tying. There is not tying in equipment market but in after-sale market. After analyzing a similar case, Eastman Kodak Co. v. Image Technical Services, Inc., we can find that the competition of equipment market don’t affect enterprise’s strategy of increasing price in after-sale market. Meanwhile, market of digital camera is developing quickly; enterprises have enough incentives to increase the price of separate part since discount value of equipment is very small. My conclusion is Sony abused tying to make super-competition profit beyond the normal scope of usage of patent right.