In 2007 the U.S. Supreme Court upended 96 years of resale price maintenance (RPM) law and applied the rule of reason, rather than the per se rule, to such agreements.1 See Leegin Creative Leather Products Inc. v. PSKS Inc., 551 U.S. 877 (2007).2

Manufacturers and lawyers who counsel them hailed Leegin as a return to rationality. Consumer advocates and certain government enforcers had the opposite reaction, decrying the decision as an invitation to price fixing.

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