Unification Church v. Bell

How later courts describe this case

• proof of predatory conduct can in some circumstances permit inferences of specific intent and dangerous probability of success
• "Thus, as stated in Hanson, average variable cost can be used as evidence of marginal cost."
• vigorous competition resulting in efficient firms driving less efficient firms out of business not proscribed by the anti-trust laws
• affirmance of directed verdict where plaintiff presented evidence of prices below cost of merchandise sold rather than average variable cost