Richard Campfield owns an auto-glass repair shop and holds fourteen patents for processes to repair or prevent windshield cracks. Although industry practice is to replace, not repair, windshields with cracks longer than 6 inches, Campfield believes that it is not only feasible, but safer, to repair cracks between 6 and 18 inches, rather than to replace the windshield. After failing to convince auto insurance companies to alter their repair policies to allow repair instead of replacement, Campfield sued State Farm Insurance Company and its agent, Lynx Services, Inc., alleging that they had engaged in illegal cooperation that resulted in a group boycott that was sufficient to show a per se violation of the Sherman Act.

State Farm is one of the largest automobile insurers in the United States. Its insureds make approximately 1.7 million claims for glass-related damage, such as windshield cracks and broken headlights, each year. State Farm contracts with glass shops to perform the needed services. State Farm outsourced management of the provision of these services to Lynx Services, Inc., a company that provides insurance claim processing services.

How should the court rule on Campfield’s allegation that State Farm and Lynx had engaged in a group boycott constituting a per se violation of the Sherman Act?