On January 8, 2026, the United States Court of Appeals for the Ninth Circuit issued [3] its opinion in Seagate Technology LLC v. NHK Spring Co., Ltd., where it addressed the extraterritorial application of U.S. antitrust law under the Foreign Trade Antitrust Improvements Act (FTAIA).

The case arose from a global price-fixing conspiracy involving suspension assemblies used in hard disk drives. Seagate Technology LLC alleged that NHK Spring Co., Ltd. conspired with competitors to fix prices worldwide, including in the United States, in violation of the Sherman Act. NHK Spring Co., Ltd. had already pleaded guilty in a separate federal criminal proceeding.

The district court granted partial summary judgment, holding that the Sherman Act did not extend to Seagate’s foreign injury. The Ninth Circuit vacated that ruling and clarified the scope and application of the FTAIA. It reaffirmed that U.S. antitrust law generally does not apply to foreign conduct unless one of two exceptions is satisfied: the “import commerce” exclusion or the “domestic effects” exception. The court rejected the applicability of the import commerce exclusion, because the price-fixed components at issue were not directly imported into the United States. The court further held that Seagate sufficiently alleged a viable claim under the FTAIA’s domestic effects exception and remanded for further proceedings.

Photo by Ken Lund (CC BY-SA 2.0)