Simonsen Sussman LLP Submits Amicus Brief for National Grocers Association and Institute for Local Self-Reliance in Ninth Circuit Robinson-Patman Act Appeal

October 2025 — New York, NY — Simonsen Sussman LLP submitted a brief of amici curiae on behalf of the National Grocers Association(NGA) and the Institute for Local Self-Reliance(ILSR) in a Ninth Circuit appeal that will clarify important issues around the elements of a Robinson-Patman Act (RPA) section 2(d) cause of action; private plaintiff standing and antitrust injury necessary to warrant injunctive relief under the Clayton Act; the difference between the threatened-injury requirement of Clayton Act section 16 (governing injunctive relief) and the actual-injury requirement of section 4 (governing damages); and the standards for entitlement to injunctive relief under the California Unfair Competition Law.

Read the full brief here.