Afederal district court Feb. 6 again dismissed all state and federal antitrust law claims asserted by specialty laboratories that alleged a conspiracy between Quest Diagnostics and several large health insurers designed to drive them out of business in California (Rheumatology Diagnostics Lab., Inc. v. Aetna, Inc., 2014 BL 32470, N.D. Cal., No. 3:12-cv-5847). The U.S. District Court for the Northern District of California ruled that the independent labs could pursue certain claims under California’s Unfair Practices Act and Unfair Competition Law but that all remaining antitrust law claims had to be dismissed. Those claims were subject to dismissal because the laboratories failed to allege adequately either an agreement between Quest and the insurance defendants or specific facts showing that Quest’s network agreements with insurers foreclosed competition in a substantial share of the relevant markets. The decision largely tracked an October 2013 ruling in which the court reached the same conclusions with respect to the antitrust law claims asserted in the independent laboratories’ first amended complaint. The second amended complaint didn’t cure the defects identified in the earlier decision, so the antitrust claims were subject to dismissal with prejudice, the court said. Violations Alleged The court addressed claims brought by Rheumatology…
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