Specht v. Cargill, Incorporated

U.S. District Court, District of Minnesota

Specht v. Cargill, Incorporated

Trial Court Opinion

                   UNITED STATES DISTRICT COURT                          
                      DISTRICT OF MINNESOTA                              
IN RE CATTLE AND BEEF ANTITRUST                                          
LITIGATION                                                               
                                     MDL No. 22-3031 (JRT/JFD)           


This Document Relates To:        MEMORANDUM OPINION AND ORDER            
                                 GRANTING DEFENDANTS’ MOTION TO          
THE INDIRECT SELLER ACTION (“Specht  DISMISS THE SPECHT AMENDED          
Case”), Civil No. 22-2903                  COMPLAINT                     


    Richard M. Paul, III, PAUL LLP, 601 Walnut Street, Suite 300, Kansas City, 
    MO 64106; Michael Montaño, GUERRA LLP, 875 East Ashby Place, Suite   
    1200, San Antonio, TX 78212, for Plaintiffs.                         

    Kosta S. Stojilkovic, WILKINSON STEKLOFF LLP, 2001 M Street, Northwest, 
    10th Floor, Washington, D.C. 20036, for Defendants Cargill, Incorporated 
    and Cargill Meat Solutions Corporation.                              

    Chelsea A. Bollman,  JONES DAY,  90 South Seventh  Street,  Suite  4950, 
    Minneapolis, MN 55402, for Defendant National Beef Packing Company,  
    LLC.                                                                 

    Jon B. Jacobs, PERKINS COIE LLP, 700 13th Street, Northwest, Suite 800, 
    Washington, D.C., 20005, for Defendants Tyson Foods, Inc., and Tyson Fresh 
    Meats, Inc.                                                          

    Jessica  J.  Nelson,  SPENCER  FANE,  100  South  Fifth  Street,  Suite  2500, 
    Minneapolis,  MN  55402,  for  Defendants  JBS  USA  Food  Company,  JBS 
    Packerland, Inc., Swift Beef Company, and JBS S.A.                   


    The putative Specht Class Members (“Plaintiffs”) filed an Amended Complaint on 
behalf of producers of feeder cattle who indirectly sell cows and calves to one or more 
Defendants  in  this  action.    Defendants  now  move  to  dismiss  Plaintiffs’  Amended 
Complaint.                                                                

    Because Plaintiffs have not clearly demonstrated that they are producers of feeder 
cattle as that term is understood by the CME Feeder Cattle Index and beef production 
industry at large, their new allegations fail to establish causation and a direct injury as 
would be necessary for antitrust standing.  The Court will therefore dismiss Plaintiffs’ 

Sherman Act, Packers and Stockyards Act, and state antitrust and consumer protection 
claims for lack of antitrust standing under Associated General Contractors of California, 
Inc. v. California State Council of Carpenters, 
459 U.S. 519
 (1983).  The Court will also 

dismiss the remaining state law claims arising under Colorado and Florida laws.   
                          BACKGROUND                                     
I.   FACTS                                                                
    The Plaintiffs’ factual allegations remain largely the same as those outlined in the 
Court’s prior order.  See In re Cattle and Beef Antitrust Litig., No. 22-3031, 
2023 WL 5310905
, at *1–2 (D. Minn. Aug. 17, 2023).  As such, the Court will only summarize and 
address newly alleged facts relevant to the current motion.               
    Cow-calf operations are the first step in the beef supply market.  (Am. Compl. ¶ 62, 
Oct. 18, 2023, Docket No. 371.)1; see also In re Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at *1 (depicting diagram of beef production market).  Cow-calf entities retain 


    1 Unless otherwise noted, all citations are to Case No. 22-3031.     
cattle for the gestation period and then raise the calves until they are weaned from their 
mothers.  (Am. Compl. ¶¶ 62–63.); In re Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, 

at *1.  After the cattle are weaned, they are raised until they are large enough for finishing 
at the feedlots—generally, when they are between 600 to 800 pounds.  (Am. Compl. ¶ 
63.)  Ranchers can raise the cattle until they are large enough for finishing and sell directly 
to a feedlot or, if the cattle are too small or light to enter the feedlot, to stockers or 

backgrounders, who will raise the cattle until they are large enough for finishing.  (Id.); In 
re  Cattle  and  Beef  Antitrust  Litig.,  
2023 WL 5310905
,  at  *1.    Feedlots  or  finishing 
operations are the final phase of the beef production system, wherein the cattle are fed 

to harvest weight.  (Am. Compl. ¶ 64.)  Once cattle reach between 950 and 1,500 pounds, 
they become fed cattle.  (Id.)  The finishing process generally takes less than 6 months.  
(Id.)  Fed cattle are sold and slaughtered at packing plants operated by packers like 
Defendants.  (Id. ¶ 66.)  The entire cattle production cycle from birth to slaughter is 

typically 15 to 24 months.  (Id. ¶ 68.)                                   
    In their Amended Complaint, Plaintiffs relabel themselves as producers of feeder 
cattle who indirectly sell cattle to one or more Defendants in this case.  (Id. ¶ 2.)  Feeder 
cattle are ultimately sold as “fat” or “fed” cattle.  (Id. ¶ 7.)  Plaintiffs define feeder cattle 

as “calves, steers, or heifers raised by cow-calf-entities, ranchers, or backgrounders in the 
United States, which feedlots use to produce fed cattle.”  (Id. ¶ 1 n.1.)  This expansion of 
Plaintiffs from cow-calf ranchers to producers of feeder cattle in effect expands to include 
all indirect sellers, including cow-calf-entities, ranchers, and  backgrounders.  (Compare 
No. 22-2903, Class Action Compl. 4 1, Oct. 31, 2022, Docket No. 1, with Am. Compl. 4] 2.) 
     Plaintiffs  reassert  the  same  price-fixing  conspiracy  by  Defendants  as  in  their 
original  complaint.  See In re Cattle and Beef Antitrust Litig.,  
2023 WL 5310905
, at *2. 
They assert that Defendants conspired to suppress the price of fed cattle, and that their 
coordinated conduct caused a collapse in fed cattle prices in 2015, which in turn caused 
the prices of feeder cattle to collapse.  (Am. Compl. 141 1, 4.)  Plaintiffs newly allege that 
Defendants’ prices for fed cattle have a direct impact on the prices that they receive for 
feeder cattle.  (/d.  7 3.)  In support, they provide the following chart comparing the CME 
Feeder Cattle Index to fed cattle prices.  (/d. 4 3, Fig. 1.) 

                     Weekly CME Feeder Cattle Index and 
                Deferred Live Cattle Contract (Adapted from CME) 
                            4-year averages: 
             deferred live cattle = $114, CME feeder cattle index = $144 
         170 
         183 
         155 
         150 
         13 
       513 
       & 125 
         120 
         ie 
         103 
         100 
         38 
           se     re     A     A     x     A     2     2     2 
                 “—=CME Feeder Cattle Index  Deferred Live Cattle 

                                    -4- 

    As the chart illustrates, Plaintiffs claim there was a correlation between fed cattle 
prices and feeder cattle prices between 2016 and 2020 that demonstrates the causal 

relationship between those prices.  (Id. ¶ 3.)                            
    Plaintiffs bring two putative classes for each claim type: a nationwide class and an 
upstream nationwide class.  (See id. ¶ 316.)  The putative nationwide classes include 
Plaintiffs who sold cattle to natural persons or entities who in turn sold to Defendants, so 

are  two  links  removed  from  Defendants’  conduct.    (Id.)    The  putative  upstream 
nationwide classes include Plaintiffs who sold cattle to intermediaries who in turn sold to 
another intermediary or a member of the nationwide classes,  so are multiple links 

removed from Defendants’ conduct.  (Id.)                                  
II.  PROCEDURAL HISTORY                                                   
    As with the factual history, the Court does not find it necessary to repeat the entire 
procedural history of this case, so it will only summarize the relevant history here.  See In 

re  Cattle and Beef  Antitrust  Litig., 
2023 WL 5310905
, at  *2–3.    The Court  granted 
Defendants’  motion  to  dismiss  Plaintiffs’  original  complaint  without  prejudice  after 
finding that Plaintiffs failed to establish antitrust standing.  Id. at *12. Plaintiffs filed the 
Amended Complaint with leave of the Court.  (See generally Am. Compl.)  Named Plaintiffs 

James Specht, Jerry Kelsey, Richard Settlemyer, and David Hyatt own and operate farms 
or ranches that raise and sell cattle at auctions, barn sales, or, for Mr. Hyatt, sometimes 
directly to a feedlot.  (Am. Compl. ¶¶ 24–27.)  Plaintiffs re-allege nationwide claims based 
on market allocation and price-fixing in violation of the Sherman Act (Count I) and the 
Packers and Stockyards Act (Count II).  (Id. ¶¶ 319–33.)  They also re-allege state law 
claims based on violations of antitrust laws (Count III) and consumer protection laws 

(Count IV).  (Id. ¶¶ 334–40.)  Defendants moved to dismiss Plaintiffs’ Amended Complaint.  
(Joint Mot. Dismiss, Nov. 21, 2023, Docket No. 453.)                      
                           DISCUSSION                                    
I.   STANDARD OF REVIEW                                                   

    In reviewing a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), the 
Court considers all facts alleged in the complaint as true to determine if the complaint 
states a “claim to relief that is plausible on its face.”  Braden v. Wal-Mart Stores, Inc., 
588 F.3d 585, 594
 (8th Cir. 2009) (quoting Ashcroft v. Iqbal, 
556 U.S. 662, 678
 (2009)).  At the 

motion to dismiss stage, the Court may consider the allegations in the complaint as well 
as “those materials that are necessarily embraced by the pleadings.”  Schriener v. Quicken 
Loans, Inc., 
774 F.3d 442, 444
 (8th Cir. 2014).                           
      “A claim has facial plausibility when the plaintiff pleads factual content that allows 

the court to draw the reasonable inference that the defendant is liable for the misconduct 
alleged.”  Iqbal, 
556 U.S. at 678
.  The Court construes the complaint in the light most 
favorable to the plaintiff, drawing all inferences in the plaintiff’s favor.  Ashley Cnty. v. 
Pfizer, Inc., 
552 F.3d 659, 665
 (8th Cir. 2009).  Although the Court accepts the complaint's 

factual allegations as true and construes the complaint in a light most favorable to the 
plaintiff, it is “not bound to accept as true a legal conclusion couched as a factual 
allegation.”  Papasan v. Allain, 
478 U.S. 265, 286
 (1986).  In other words, a complaint 
“does not need detailed factual allegations” but must include more “than labels and 
conclusions, and a formulaic recitation of the elements” to meet the plausibility standard.  

Bell Atl. Corp. v. Twombly, 
550 U.S. 544, 555
 (2007).                     
II.  ANALYSIS                                                             
    Defendants argue that the Amended Complaint still fails to adequately establish 
antitrust standing as is required for many of Plaintiffs’ claims under Associated General 

Contractors of California, Inc. v. California State Council of Carpenters (“AGC”), 
459 U.S. 519
  (1983).    They  also  claim  that  Plaintiffs’  remaining  state  law  claims  should  be 
dismissed.  The Court will address each issue in turn.                    
    A.   Antitrust Standing                                              

    The Amended Complaint brings antitrust claims under the Sherman Act and the 
antitrust laws of 30 states.2  It also brings consumer protection claims under the laws of 
12 states.3  The Court previously found that Plaintiffs must show antitrust standing not 
only for their claims under the Sherman Act and many of the state antitrust laws, but also 

for their claims under the Packers and Stockyards Act (“PSA”) and many of the state 



    2 Plaintiffs bring antitrust claims on behalf of state law damages classes in Alabama, 
Arizona, Arkansas, California, Connecticut, District of Columbia, Hawaii, Illinois, Iowa, Kansas, 
Maine, Maryland, Michigan, Minnesota, Mississippi, Nebraska, Nevada, New Hampshire, New 
Mexico,  New  York,  North  Carolina,  North  Dakota,  Oregon,  Rhode  Island,  South  Dakota, 
Tennessee, Utah, Vermont, West Virginia, and Wisconsin. (Am. Compl. ¶ 335.) 
    3 Plaintiffs bring state consumer protection claims on behalf of state law damages classes 
in Arizona, California, Colorado, Florida, Illinois, Nevada, New Mexico, New York, North Carolina, 
Oregon, Tennessee, and Wisconsin.  (Am. Compl. ¶ 339.)                    
consumer protection laws.  In re Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at *4, 
8–9.                                                                      

    AGC establishes six factors to determine whether a plaintiff has antitrust standing: 
         (1)  The  causal  connection  between  the  alleged  antitrust  
         violation and the harm to the plaintiff; (2) Improper motive;   
         (3) Whether the injury was of a type that Congress sought to    
         redress with the antitrust laws; (4) The directness between     
         the injury and the market restraint; (5) The speculative nature 
         of  the  damages;  (6)  The  risk  of  duplicate  recoveries  or 
         complex damage apportionment.                                   

Midwest Commc’ns v. Minn. Twins, Inc., 
779 F.2d 444
, 450 n.6 (8th Cir. 1985).  This inquiry 
essentially results in a determination of whether “the plaintiff [is] the target of the 
anticompetitive activity, not one who has merely suffered indirect, secondary, or remote 
injury.”  
Id. at 451
 (citation and internal quotations omitted).  The Court will analyze each 
factor in turn.                                                           
         1.   Causal Connection                                          
    The Court must first consider the “causal connection between the alleged antitrust 
violation and the harm to the plaintiff.”  McDonald v. Johnson & Johnson, 
722 F.2d 1370, 1374
 (8th Cir. 1983).  The Court previously found this factor weighed against antitrust 
standing because Plaintiffs failed to allege how manipulating fed cattle prices impacted 
cow-calf prices.  In re Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at *4–5.  Plaintiffs, 
relabeled as producers of feeder cattle, newly allege that Defendants’ conduct directly 
impacts the price of feeder cattle, as demonstrated by the chart comparing the CME 
Feeder Cattle Index to fed cattle prices.  Plaintiffs also point to statements by industry 
experts who claim that “[t]he most important factor influencing feeder cattle prices is the 
price of the animal when finished,” and that “[f]eeder cattle markets are expectation 

markets that are primarily driven by two things: (1) the expected value of fed cattle in the 
future and (2) the cost of getting those feeder cattle to that point.”  (Am. Compl. ¶¶ 236, 
239.)                                                                     
    While Plaintiffs have alleged that feeder cattle prices are determined—at least in 

part—by fed cattle prices, their allegations depend on one key fact: whether Plaintiffs are 
producers of feeder cattle as that term is understood by the industry.  If they are not, 
then they have failed to establish a causal connection, because the CME Feeder Cattle 

Index and industry data on which they newly rely pertain to feeder cattle.   
    The industry appears to define feeder cattle as cattle that are put onto feedlots for 
slaughter that are of a certain weight and frame type.4  Most notably, the CME Feeder 
Cattle Index, upon which Plaintiffs rely substantially in alleging a relationship between 

feeder cattle and fed cattle, refers to feeder cattle as medium and large frame cattle 
“being placed on feed at the feedlot” that are between 700 to 899 pounds.5  This 



    4  See  Hedging  with  the  CME  Feeder  Cattle  Index  (Dec.  21,  2018), 
https://www.cmegroup.com/education/articles-and-reports/hedging-with-the-cme-feeder-
cattle-index-white-paper.html.                                            
    5 Compare Hedging with the CME Feeder Cattle Index, and CME Rulebook Chapter 102, 
Feeder    Cattle   Futures,   Section   10203.A,    available  at         
https://www.cmegroup.com/content/dam/cmegroup/rulebook/CME/II/100/102/102.pdf (“The 
CME Feeder Cattle Index™ is based upon a sample of transactions from these weight/frame score 
categories: 700 to 899 pound Medium and Large Frame #1 feeder steers, and 700 to 899 pound 
definition of feeder cattle is far narrower than the one Plaintiffs are using and indicates 
that only Plaintiffs who sell cattle directly to feedlots of a certain weight and frame type 

are producers of feeder cattle as that term is understood by the CME Feeder Cattle Index 
and the industry at large.  And only one named plaintiff, Hyatt, has alleged that he sold 
cattle directly to a feedlot, although his allegations fail to specify the weight or frame type 
of the cattle he allegedly sold.  What’s more, Hyatt only claims to have sold “one or two 

loads of feeder cattle directly to a feedlot,” and only “[f]or the past two years.”  (Am. 
Compl. ¶ 27.)  Thus, the causal connection between Defendants’ conduct and Plaintiffs’ 
harm is still attenuated, as only one named Plaintiff could conceivably qualify as a 

producer of feeder cattle, and even that characterization is a stretch.  More substantial 
allegations regarding Plaintiffs’ direct-to-feedlot sales could be sufficient, but based on 
the allegations in the Amended Complaint the Court finds that Plaintiffs have not clearly 
demonstrated that they are producers of feeder cattle.                    

    Moreover, Plaintiffs have still not clearly alleged that they were the target of the 
alleged conspiracy as required for antitrust standing.  Minn. Twins, 
779 F.2d at 451
.  It is 
insufficient for Plaintiffs to have “merely suffered indirect, secondary, or remote injury.”  
Id.
  (quotation  omitted).    Plaintiffs  assert  that  they  were  the  target  of  the  alleged 

conspiracy because they are producers of feeder cattle, which is in the same market as 



Medium and Large Frame #1-2 feeder steers.”), with (Am. Compl. ¶ 3, Fig. 1 (citing to CME Feeder 
Cattle Index).).                                                          
the fed cattle.  However, the Court previously determined that “the calves that Plaintiffs 
raise are inherently different than the full-grown cattle that Defendants process,” and 

that Plaintiffs failed to demonstrate that they are in the same market as Defendants.  In 
re Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at *6.  Furthermore, Plaintiffs 
continue to rely on inferences about the market generally, which the Court previously 
found insufficient.  See 
id.
 at *5 (citing McDonald, 
722 F.2d at 1374
).  This factor therefore 

continues to weigh against antitrust standing.                            
         2.   Improper Motive                                            
    The next factor is whether there was any improper motive on the part of the 
Defendants.  McDonald, 
722 F.2d at 1374
.  The Court previously held that “[w]hile 

motivation to increase profits is not inherently improper, this factor weighs in favor of 
antitrust standing given the broader context of Plaintiffs’ price-fixing allegations.”  In re 
Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at *5.  Because the allegations upon 

which the Court reached that conclusion are substantially re-alleged in the Amended 
Complaint, this factor again weighs in favor of antitrust standing.       
         3.   Type of Injury                                             
    The Court must next consider if “the injury was of a type that Congress sought to 
redress with antitrust laws.”  McDonald, 
722 F.2d at 1374
.  A party can show that they 

have  suffered  the  type  of  injury  that  Congress  sought  to  protect  if  their  injury  is 
“inextricably intertwined with the injury the conspiracies sought to inflict on . . . the 
[relevant] market.”  Blue Shield of Virginia v. McCready, 
457 U.S. 465, 484
 (1982).  The 
Court previously found this factor was neutral.  In re Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at *6.                                                        

    The Court reaches the same conclusion here.  On the one hand, Plaintiffs re-allege 
the same injuries which the Court previously found suggest the  type of injury that 
Congress sought to redress.  
Id.
  For example, they contend that they were injured by 
Defendants’ anticompetitive conduct, deprived of fair price competition at the top of the 

supply chain, and that consumers were overcharged at the bottom of the supply chain.  
(Am. Compl.  ¶¶  3,  6.)   But  on  the  other hand,  the  new  allegations do  not  clearly 
demonstrate that Plaintiffs are in the same relevant market as the alleged conspiracy. 

    Although Plaintiffs newly allege that all cattle are inherently the same product, 
even though the ownership of the cattle may pass through several hands from birth to 
slaughter, the calves that Plaintiffs raise are inherently different than the full-grown cattle 
that Defendants process.  See In re Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at 

*6.  That said, the markets for products and for sub-products contained in the product 
may be “inextricably linked.”  E.g., In re TFT-LCD (Flat Panel) Antitrust Litig., 
586 F. Supp. 2d 1109, 1123
 (N.D. Cal. 2008).  So, producers of feeder cattle may be in the relevant 
market because feeder cattle are raised to be fed cattle and the Plaintiffs have alleged a 

relationship between those markets.  But whether Plaintiffs are producers of feeder cattle 
is not supported by the facts alleged in the Amended Complaint.  Plaintiffs have not clearly 
established that they are producers of feeder cattle as that term is understood by the 
industry.  There are still too many chains in the link between Plaintiffs and Defendants 
that make Plaintiffs’ alleged injury too remote.  See Southwest Suburban Bd. of Realtors, 

Inc. v. Beverly Area Plan. Ass’n, 
830 F.2d 1374, 1379
 (7th Cir. 1987) (“[A]s a general rule 
suppliers of an injured customer may not seek recovery under the antitrust laws because 
their injuries are too ‘indirect, secondary, or remote.’”).  Accordingly, this factor is again 
neutral.                                                                  

         4.   Directness                                                 
    The Court must next consider the directness between the injury and the market 
restraint, which requires consideration of the “chain of causation.”  McDonald, 
722 F.2d at 1374
; AGC, 
459 U.S. at 540
.  The Court previously found this factor weighs against 

antitrust standing because Plaintiffs failed to explain how their decreased profits are 
traceable to the Defendants’ conduct.  In re Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at *6.  Plaintiffs relied on inferences about the market, which the Court found 

to be unsupported by sufficient factual allegations.  
Id.
                 
    Here, Plaintiffs allege they are several steps removed from Defendants’ alleged 
market manipulation, but that the relationship between the feeder cattle and fed cattle 
markets demonstrates a direct chain of causation between Defendants’ conduct and 

Plaintiffs’ harm.  An indirect plaintiff’s injury may be adequately traceable through the 
product distribution chain to show directness.  E.g., In re Cattle and Beef Antitrust Litig., 
No. 19-1129, 
2021 WL 7757881
, at *11 (D. Minn. Sept. 14, 2021); In re Broiler Chicken 
Antitrust Litig., 
290 F. Supp. 3d 772, 814
 (N.D. Ill. 2017).  But Plaintiffs still must establish 
directness that is not “too remote.”  In re Dynamic Random Access Memory Antitrust 
Litig., 
516 F. Supp. 2d 1072, 1092
 (N.D. Cal. 2007).                      

    While  Plaintiffs  have  provided  more  substantial  allegations  regarding  the 
traceability of Defendants’ conduct to the feeder cattle market, the chain of causation 
depends on whether Plaintiffs are producers of feeder cattle.  And, as explained above, 
Plaintiffs have not clearly demonstrated that they are such producers.  Without that 

necessary fact, Plaintiffs’ allegations are largely the same as before.  This factor therefore 
weighs against standing.                                                  
         5.   Speculative Nature of Damages                              
    The fifth factor is the speculative nature of the damages.  McDonald, 
722 F.2d at 1374
.  The Court previously found this factor neutral because even though other factors 
may affect cow-calf prices, similar meat packing antitrust cases have considered the 
speculative nature of damages and determined that there are means and methods for 

economic analysts to pinpoint prices that would have been paid but for the conspiracy.  
In re Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at *7.  Similarly, here, the fact that 
multiple other factors may affect the prices of the cattle Plaintiffs produce in addition to 
Defendants’ conduct is not dispositive.                                   

    Defendants argue that Plaintiffs fail to account for certain complexities inherent in 
the new proposed classes, such as the fact that harm to one sector may benefit another.  
For example, if cow-calf prices drop, cow-calf ranchers are harmed, but backgrounders or 
stockers  could  be  better  off  as  their  input  costs  to  acquire  calves  decreases.    But 
regression analysis may be used to narrow down various supply and demand factors to 
pinpoint the damages exclusively caused by any alleged market manipulation, regardless 

of the complexities that the new proposed classes may bring.  See In re Pork Antitrust 
Litig., 
665 F. Supp. 3d 967
, 991–92 (D. Minn. 2023).  This factor is therefore neutral. 
         6.   Risk of Duplicative Recovery                               
    The  last  factor  is  the  “risk  of  duplicative  recoveries  or  complex  damage 

apportionment.”  McDonald, 
722 F.2d at 1343
.  The Court previously found this factor 
weighed in favor of antitrust standing, unconvinced that it would be difficult for the 
parties to conduct economic analysis to ascertain an appropriate damages amount.  In re 
Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at *7.  The Court reaches the same 

conclusion here.  Though Defendants argue that the expansion of Plaintiffs to include all 
indirect sellers makes apportionment more complex and creates a risk of duplicative 
recoveries, economic analyses are capable of ascertaining Plaintiffs’ injuries to avoid 

duplicative recovery.  Therefore, this factor continues to favor antitrust standing.  
                          *    *    *                                    
    Weighing the six AGC factors, the Court finds that Plaintiffs failed to establish 
antitrust standing under AGC.  Because Plaintiffs have not clearly demonstrated that they 

are producers of feeder cattle as understood by the CME Feeder Cattle Index and beef 
production  industry  at  large,  the  Amended  Complaint’s  allegations  regarding  the 
relationship  between  the  fed  cattle  and  the  feeder  cattle  markets  do  not  support 
Plaintiffs’ antitrust standing.  Without more substantial allegations that Plaintiffs are 
producers of feeder cattle, they have not plausibly alleged a causal relationship between 
Defendants’ conduct  and their injury, or that their injury and damages are directly 

traceable to Defendants’ conduct.                                         
    Because Plaintiffs have not established antitrust standing, the Court will dismiss 
Plaintiffs’ Sherman Act, PSA, and state antitrust and consumer protection claims in the 
states that apply AGC.  See 
id.
 at *7 n.5 (listing states).  The Court will also dismiss the only 

remaining  state  antitrust  law  claim  that  does  not  apply  AGC,  which  arises  under 
Minnesota  law.    Even  though  Minnesota  does  not  explicitly  apply  AGC,  it  similarly 
considers proximate causation and directness, which Plaintiffs failed to establish.  See id. 

at *7.                                                                    
    B.   Remaining State Law Claims                                      
    The only remaining claims are Plaintiffs’ consumer protection claims arising under 
Florida and Colorado law, which the Court previously dismissed for lack of proximate 

causation or insufficient pleading of specific harm.  Id. at *9–10.  Because Plaintiffs have 
again failed to establish proximate causation, the Court will dismiss the Florida consumer 
protection claim.  Defendants argue that Plaintiffs’ Colorado consumer protection claim 
fails  because  Plaintiffs  failed  to  allege  that  they  were  injured  by  Defendants’ 

misrepresentations, as required by Colorado law.  See id. at *9.  Though Plaintiffs allege 
they were unable to discern how Defendants’ misrepresentations specifically injured 
them because of Defendants’ fraudulent concealment, the Court previously found such 
these allegations were insufficient.  See id. at *9.  Thus, Plaintiffs have again failed to 
demonstrate how Defendants’ misrepresentations specifically injured Plaintiffs.  The 
Court will therefore dismiss Plaintiffs’ Florida and Colorado consumer protection claims.   

                          CONCLUSION                                     
    The  Court  will  dismiss  Plaintiffs’  Sherman  Act,  PSA,  and  state  antitrust  and 
consumer  protection  claims  for  lack  of  antitrust  standing  under  AGC.    Though  the 
Amended Complaint alleges a relationship between the prices and markets of feeder 

cattle and fed cattle, Plaintiffs have not clearly established that they are producers of 
feeder cattle, so these new allegations are insufficient to establish proximate causation 
and directness.  The Court will also dismiss the remaining state law claims arising under 
Minnesota, Colorado, and Florida laws.                                    

ORDER

    Based on the foregoing, and all the files, records, and proceedings herein, IT IS 
HEREBY ORDERED that:                                                      
    1.  Defendants’ Motion to Dismiss the Amended Specht Complaint [Docket No. 

      453] is GRANTED; and                                               
    2.  Plaintiffs’  Amended  Complaint  [Docket  No.  371]  is  DISMISSED  without 
      prejudice.                                                         
     LET JUDGMENT BE ENTERED ACCORDINGLY. 

DATED:  May 24, 2024                              Otay    | table 
at Minneapolis, Minnesota.                         JOHN R. TUNHEIM 
                                            United States District Judge 

                                    -18- 

Trial Court Opinion

                   UNITED STATES DISTRICT COURT                          
                      DISTRICT OF MINNESOTA                              
IN RE CATTLE AND BEEF ANTITRUST                                          
LITIGATION                                                               
                                     MDL No. 22-3031 (JRT/JFD)           


This Document Relates To:        MEMORANDUM OPINION AND ORDER            
                                 GRANTING DEFENDANTS’ MOTION TO          
THE INDIRECT SELLER ACTION (“Specht  DISMISS THE SPECHT AMENDED          
Case”), Civil No. 22-2903                  COMPLAINT                     


    Richard M. Paul, III, PAUL LLP, 601 Walnut Street, Suite 300, Kansas City, 
    MO 64106; Michael Montaño, GUERRA LLP, 875 East Ashby Place, Suite   
    1200, San Antonio, TX 78212, for Plaintiffs.                         

    Kosta S. Stojilkovic, WILKINSON STEKLOFF LLP, 2001 M Street, Northwest, 
    10th Floor, Washington, D.C. 20036, for Defendants Cargill, Incorporated 
    and Cargill Meat Solutions Corporation.                              

    Chelsea A. Bollman,  JONES DAY,  90 South Seventh  Street,  Suite  4950, 
    Minneapolis, MN 55402, for Defendant National Beef Packing Company,  
    LLC.                                                                 

    Jon B. Jacobs, PERKINS COIE LLP, 700 13th Street, Northwest, Suite 800, 
    Washington, D.C., 20005, for Defendants Tyson Foods, Inc., and Tyson Fresh 
    Meats, Inc.                                                          

    Jessica  J.  Nelson,  SPENCER  FANE,  100  South  Fifth  Street,  Suite  2500, 
    Minneapolis,  MN  55402,  for  Defendants  JBS  USA  Food  Company,  JBS 
    Packerland, Inc., Swift Beef Company, and JBS S.A.                   


    The putative Specht Class Members (“Plaintiffs”) filed an Amended Complaint on 
behalf of producers of feeder cattle who indirectly sell cows and calves to one or more 
Defendants  in  this  action.    Defendants  now  move  to  dismiss  Plaintiffs’  Amended 
Complaint.                                                                

    Because Plaintiffs have not clearly demonstrated that they are producers of feeder 
cattle as that term is understood by the CME Feeder Cattle Index and beef production 
industry at large, their new allegations fail to establish causation and a direct injury as 
would be necessary for antitrust standing.  The Court will therefore dismiss Plaintiffs’ 

Sherman Act, Packers and Stockyards Act, and state antitrust and consumer protection 
claims for lack of antitrust standing under Associated General Contractors of California, 
Inc. v. California State Council of Carpenters, 
459 U.S. 519
 (1983).  The Court will also 

dismiss the remaining state law claims arising under Colorado and Florida laws.   
                          BACKGROUND                                     
I.   FACTS                                                                
    The Plaintiffs’ factual allegations remain largely the same as those outlined in the 
Court’s prior order.  See In re Cattle and Beef Antitrust Litig., No. 22-3031, 
2023 WL 5310905
, at *1–2 (D. Minn. Aug. 17, 2023).  As such, the Court will only summarize and 
address newly alleged facts relevant to the current motion.               
    Cow-calf operations are the first step in the beef supply market.  (Am. Compl. ¶ 62, 
Oct. 18, 2023, Docket No. 371.)1; see also In re Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at *1 (depicting diagram of beef production market).  Cow-calf entities retain 


    1 Unless otherwise noted, all citations are to Case No. 22-3031.     
cattle for the gestation period and then raise the calves until they are weaned from their 
mothers.  (Am. Compl. ¶¶ 62–63.); In re Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, 

at *1.  After the cattle are weaned, they are raised until they are large enough for finishing 
at the feedlots—generally, when they are between 600 to 800 pounds.  (Am. Compl. ¶ 
63.)  Ranchers can raise the cattle until they are large enough for finishing and sell directly 
to a feedlot or, if the cattle are too small or light to enter the feedlot, to stockers or 

backgrounders, who will raise the cattle until they are large enough for finishing.  (Id.); In 
re  Cattle  and  Beef  Antitrust  Litig.,  
2023 WL 5310905
,  at  *1.    Feedlots  or  finishing 
operations are the final phase of the beef production system, wherein the cattle are fed 

to harvest weight.  (Am. Compl. ¶ 64.)  Once cattle reach between 950 and 1,500 pounds, 
they become fed cattle.  (Id.)  The finishing process generally takes less than 6 months.  
(Id.)  Fed cattle are sold and slaughtered at packing plants operated by packers like 
Defendants.  (Id. ¶ 66.)  The entire cattle production cycle from birth to slaughter is 

typically 15 to 24 months.  (Id. ¶ 68.)                                   
    In their Amended Complaint, Plaintiffs relabel themselves as producers of feeder 
cattle who indirectly sell cattle to one or more Defendants in this case.  (Id. ¶ 2.)  Feeder 
cattle are ultimately sold as “fat” or “fed” cattle.  (Id. ¶ 7.)  Plaintiffs define feeder cattle 

as “calves, steers, or heifers raised by cow-calf-entities, ranchers, or backgrounders in the 
United States, which feedlots use to produce fed cattle.”  (Id. ¶ 1 n.1.)  This expansion of 
Plaintiffs from cow-calf ranchers to producers of feeder cattle in effect expands to include 
all indirect sellers, including cow-calf-entities, ranchers, and  backgrounders.  (Compare 
No. 22-2903, Class Action Compl. 4 1, Oct. 31, 2022, Docket No. 1, with Am. Compl. 4] 2.) 
     Plaintiffs  reassert  the  same  price-fixing  conspiracy  by  Defendants  as  in  their 
original  complaint.  See In re Cattle and Beef Antitrust Litig.,  
2023 WL 5310905
, at *2. 
They assert that Defendants conspired to suppress the price of fed cattle, and that their 
coordinated conduct caused a collapse in fed cattle prices in 2015, which in turn caused 
the prices of feeder cattle to collapse.  (Am. Compl. 141 1, 4.)  Plaintiffs newly allege that 
Defendants’ prices for fed cattle have a direct impact on the prices that they receive for 
feeder cattle.  (/d.  7 3.)  In support, they provide the following chart comparing the CME 
Feeder Cattle Index to fed cattle prices.  (/d. 4 3, Fig. 1.) 

                     Weekly CME Feeder Cattle Index and 
                Deferred Live Cattle Contract (Adapted from CME) 
                            4-year averages: 
             deferred live cattle = $114, CME feeder cattle index = $144 
         170 
         183 
         155 
         150 
         13 
       513 
       & 125 
         120 
         ie 
         103 
         100 
         38 
           se     re     A     A     x     A     2     2     2 
                 “—=CME Feeder Cattle Index  Deferred Live Cattle 

                                    -4- 

    As the chart illustrates, Plaintiffs claim there was a correlation between fed cattle 
prices and feeder cattle prices between 2016 and 2020 that demonstrates the causal 

relationship between those prices.  (Id. ¶ 3.)                            
    Plaintiffs bring two putative classes for each claim type: a nationwide class and an 
upstream nationwide class.  (See id. ¶ 316.)  The putative nationwide classes include 
Plaintiffs who sold cattle to natural persons or entities who in turn sold to Defendants, so 

are  two  links  removed  from  Defendants’  conduct.    (Id.)    The  putative  upstream 
nationwide classes include Plaintiffs who sold cattle to intermediaries who in turn sold to 
another intermediary or a member of the nationwide classes,  so are multiple links 

removed from Defendants’ conduct.  (Id.)                                  
II.  PROCEDURAL HISTORY                                                   
    As with the factual history, the Court does not find it necessary to repeat the entire 
procedural history of this case, so it will only summarize the relevant history here.  See In 

re  Cattle and Beef  Antitrust  Litig., 
2023 WL 5310905
, at  *2–3.    The Court  granted 
Defendants’  motion  to  dismiss  Plaintiffs’  original  complaint  without  prejudice  after 
finding that Plaintiffs failed to establish antitrust standing.  Id. at *12. Plaintiffs filed the 
Amended Complaint with leave of the Court.  (See generally Am. Compl.)  Named Plaintiffs 

James Specht, Jerry Kelsey, Richard Settlemyer, and David Hyatt own and operate farms 
or ranches that raise and sell cattle at auctions, barn sales, or, for Mr. Hyatt, sometimes 
directly to a feedlot.  (Am. Compl. ¶¶ 24–27.)  Plaintiffs re-allege nationwide claims based 
on market allocation and price-fixing in violation of the Sherman Act (Count I) and the 
Packers and Stockyards Act (Count II).  (Id. ¶¶ 319–33.)  They also re-allege state law 
claims based on violations of antitrust laws (Count III) and consumer protection laws 

(Count IV).  (Id. ¶¶ 334–40.)  Defendants moved to dismiss Plaintiffs’ Amended Complaint.  
(Joint Mot. Dismiss, Nov. 21, 2023, Docket No. 453.)                      
                           DISCUSSION                                    
I.   STANDARD OF REVIEW                                                   

    In reviewing a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), the 
Court considers all facts alleged in the complaint as true to determine if the complaint 
states a “claim to relief that is plausible on its face.”  Braden v. Wal-Mart Stores, Inc., 
588 F.3d 585, 594
 (8th Cir. 2009) (quoting Ashcroft v. Iqbal, 
556 U.S. 662, 678
 (2009)).  At the 

motion to dismiss stage, the Court may consider the allegations in the complaint as well 
as “those materials that are necessarily embraced by the pleadings.”  Schriener v. Quicken 
Loans, Inc., 
774 F.3d 442, 444
 (8th Cir. 2014).                           
      “A claim has facial plausibility when the plaintiff pleads factual content that allows 

the court to draw the reasonable inference that the defendant is liable for the misconduct 
alleged.”  Iqbal, 
556 U.S. at 678
.  The Court construes the complaint in the light most 
favorable to the plaintiff, drawing all inferences in the plaintiff’s favor.  Ashley Cnty. v. 
Pfizer, Inc., 
552 F.3d 659, 665
 (8th Cir. 2009).  Although the Court accepts the complaint's 

factual allegations as true and construes the complaint in a light most favorable to the 
plaintiff, it is “not bound to accept as true a legal conclusion couched as a factual 
allegation.”  Papasan v. Allain, 
478 U.S. 265, 286
 (1986).  In other words, a complaint 
“does not need detailed factual allegations” but must include more “than labels and 
conclusions, and a formulaic recitation of the elements” to meet the plausibility standard.  

Bell Atl. Corp. v. Twombly, 
550 U.S. 544, 555
 (2007).                     
II.  ANALYSIS                                                             
    Defendants argue that the Amended Complaint still fails to adequately establish 
antitrust standing as is required for many of Plaintiffs’ claims under Associated General 

Contractors of California, Inc. v. California State Council of Carpenters (“AGC”), 
459 U.S. 519
  (1983).    They  also  claim  that  Plaintiffs’  remaining  state  law  claims  should  be 
dismissed.  The Court will address each issue in turn.                    
    A.   Antitrust Standing                                              

    The Amended Complaint brings antitrust claims under the Sherman Act and the 
antitrust laws of 30 states.2  It also brings consumer protection claims under the laws of 
12 states.3  The Court previously found that Plaintiffs must show antitrust standing not 
only for their claims under the Sherman Act and many of the state antitrust laws, but also 

for their claims under the Packers and Stockyards Act (“PSA”) and many of the state 



    2 Plaintiffs bring antitrust claims on behalf of state law damages classes in Alabama, 
Arizona, Arkansas, California, Connecticut, District of Columbia, Hawaii, Illinois, Iowa, Kansas, 
Maine, Maryland, Michigan, Minnesota, Mississippi, Nebraska, Nevada, New Hampshire, New 
Mexico,  New  York,  North  Carolina,  North  Dakota,  Oregon,  Rhode  Island,  South  Dakota, 
Tennessee, Utah, Vermont, West Virginia, and Wisconsin. (Am. Compl. ¶ 335.) 
    3 Plaintiffs bring state consumer protection claims on behalf of state law damages classes 
in Arizona, California, Colorado, Florida, Illinois, Nevada, New Mexico, New York, North Carolina, 
Oregon, Tennessee, and Wisconsin.  (Am. Compl. ¶ 339.)                    
consumer protection laws.  In re Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at *4, 
8–9.                                                                      

    AGC establishes six factors to determine whether a plaintiff has antitrust standing: 
         (1)  The  causal  connection  between  the  alleged  antitrust  
         violation and the harm to the plaintiff; (2) Improper motive;   
         (3) Whether the injury was of a type that Congress sought to    
         redress with the antitrust laws; (4) The directness between     
         the injury and the market restraint; (5) The speculative nature 
         of  the  damages;  (6)  The  risk  of  duplicate  recoveries  or 
         complex damage apportionment.                                   

Midwest Commc’ns v. Minn. Twins, Inc., 
779 F.2d 444
, 450 n.6 (8th Cir. 1985).  This inquiry 
essentially results in a determination of whether “the plaintiff [is] the target of the 
anticompetitive activity, not one who has merely suffered indirect, secondary, or remote 
injury.”  
Id. at 451
 (citation and internal quotations omitted).  The Court will analyze each 
factor in turn.                                                           
         1.   Causal Connection                                          
    The Court must first consider the “causal connection between the alleged antitrust 
violation and the harm to the plaintiff.”  McDonald v. Johnson & Johnson, 
722 F.2d 1370, 1374
 (8th Cir. 1983).  The Court previously found this factor weighed against antitrust 
standing because Plaintiffs failed to allege how manipulating fed cattle prices impacted 
cow-calf prices.  In re Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at *4–5.  Plaintiffs, 
relabeled as producers of feeder cattle, newly allege that Defendants’ conduct directly 
impacts the price of feeder cattle, as demonstrated by the chart comparing the CME 
Feeder Cattle Index to fed cattle prices.  Plaintiffs also point to statements by industry 
experts who claim that “[t]he most important factor influencing feeder cattle prices is the 
price of the animal when finished,” and that “[f]eeder cattle markets are expectation 

markets that are primarily driven by two things: (1) the expected value of fed cattle in the 
future and (2) the cost of getting those feeder cattle to that point.”  (Am. Compl. ¶¶ 236, 
239.)                                                                     
    While Plaintiffs have alleged that feeder cattle prices are determined—at least in 

part—by fed cattle prices, their allegations depend on one key fact: whether Plaintiffs are 
producers of feeder cattle as that term is understood by the industry.  If they are not, 
then they have failed to establish a causal connection, because the CME Feeder Cattle 

Index and industry data on which they newly rely pertain to feeder cattle.   
    The industry appears to define feeder cattle as cattle that are put onto feedlots for 
slaughter that are of a certain weight and frame type.4  Most notably, the CME Feeder 
Cattle Index, upon which Plaintiffs rely substantially in alleging a relationship between 

feeder cattle and fed cattle, refers to feeder cattle as medium and large frame cattle 
“being placed on feed at the feedlot” that are between 700 to 899 pounds.5  This 



    4  See  Hedging  with  the  CME  Feeder  Cattle  Index  (Dec.  21,  2018), 
https://www.cmegroup.com/education/articles-and-reports/hedging-with-the-cme-feeder-
cattle-index-white-paper.html.                                            
    5 Compare Hedging with the CME Feeder Cattle Index, and CME Rulebook Chapter 102, 
Feeder    Cattle   Futures,   Section   10203.A,    available  at         
https://www.cmegroup.com/content/dam/cmegroup/rulebook/CME/II/100/102/102.pdf (“The 
CME Feeder Cattle Index™ is based upon a sample of transactions from these weight/frame score 
categories: 700 to 899 pound Medium and Large Frame #1 feeder steers, and 700 to 899 pound 
definition of feeder cattle is far narrower than the one Plaintiffs are using and indicates 
that only Plaintiffs who sell cattle directly to feedlots of a certain weight and frame type 

are producers of feeder cattle as that term is understood by the CME Feeder Cattle Index 
and the industry at large.  And only one named plaintiff, Hyatt, has alleged that he sold 
cattle directly to a feedlot, although his allegations fail to specify the weight or frame type 
of the cattle he allegedly sold.  What’s more, Hyatt only claims to have sold “one or two 

loads of feeder cattle directly to a feedlot,” and only “[f]or the past two years.”  (Am. 
Compl. ¶ 27.)  Thus, the causal connection between Defendants’ conduct and Plaintiffs’ 
harm is still attenuated, as only one named Plaintiff could conceivably qualify as a 

producer of feeder cattle, and even that characterization is a stretch.  More substantial 
allegations regarding Plaintiffs’ direct-to-feedlot sales could be sufficient, but based on 
the allegations in the Amended Complaint the Court finds that Plaintiffs have not clearly 
demonstrated that they are producers of feeder cattle.                    

    Moreover, Plaintiffs have still not clearly alleged that they were the target of the 
alleged conspiracy as required for antitrust standing.  Minn. Twins, 
779 F.2d at 451
.  It is 
insufficient for Plaintiffs to have “merely suffered indirect, secondary, or remote injury.”  
Id.
  (quotation  omitted).    Plaintiffs  assert  that  they  were  the  target  of  the  alleged 

conspiracy because they are producers of feeder cattle, which is in the same market as 



Medium and Large Frame #1-2 feeder steers.”), with (Am. Compl. ¶ 3, Fig. 1 (citing to CME Feeder 
Cattle Index).).                                                          
the fed cattle.  However, the Court previously determined that “the calves that Plaintiffs 
raise are inherently different than the full-grown cattle that Defendants process,” and 

that Plaintiffs failed to demonstrate that they are in the same market as Defendants.  In 
re Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at *6.  Furthermore, Plaintiffs 
continue to rely on inferences about the market generally, which the Court previously 
found insufficient.  See 
id.
 at *5 (citing McDonald, 
722 F.2d at 1374
).  This factor therefore 

continues to weigh against antitrust standing.                            
         2.   Improper Motive                                            
    The next factor is whether there was any improper motive on the part of the 
Defendants.  McDonald, 
722 F.2d at 1374
.  The Court previously held that “[w]hile 

motivation to increase profits is not inherently improper, this factor weighs in favor of 
antitrust standing given the broader context of Plaintiffs’ price-fixing allegations.”  In re 
Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at *5.  Because the allegations upon 

which the Court reached that conclusion are substantially re-alleged in the Amended 
Complaint, this factor again weighs in favor of antitrust standing.       
         3.   Type of Injury                                             
    The Court must next consider if “the injury was of a type that Congress sought to 
redress with antitrust laws.”  McDonald, 
722 F.2d at 1374
.  A party can show that they 

have  suffered  the  type  of  injury  that  Congress  sought  to  protect  if  their  injury  is 
“inextricably intertwined with the injury the conspiracies sought to inflict on . . . the 
[relevant] market.”  Blue Shield of Virginia v. McCready, 
457 U.S. 465, 484
 (1982).  The 
Court previously found this factor was neutral.  In re Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at *6.                                                        

    The Court reaches the same conclusion here.  On the one hand, Plaintiffs re-allege 
the same injuries which the Court previously found suggest the  type of injury that 
Congress sought to redress.  
Id.
  For example, they contend that they were injured by 
Defendants’ anticompetitive conduct, deprived of fair price competition at the top of the 

supply chain, and that consumers were overcharged at the bottom of the supply chain.  
(Am. Compl.  ¶¶  3,  6.)   But  on  the  other hand,  the  new  allegations do  not  clearly 
demonstrate that Plaintiffs are in the same relevant market as the alleged conspiracy. 

    Although Plaintiffs newly allege that all cattle are inherently the same product, 
even though the ownership of the cattle may pass through several hands from birth to 
slaughter, the calves that Plaintiffs raise are inherently different than the full-grown cattle 
that Defendants process.  See In re Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at 

*6.  That said, the markets for products and for sub-products contained in the product 
may be “inextricably linked.”  E.g., In re TFT-LCD (Flat Panel) Antitrust Litig., 
586 F. Supp. 2d 1109, 1123
 (N.D. Cal. 2008).  So, producers of feeder cattle may be in the relevant 
market because feeder cattle are raised to be fed cattle and the Plaintiffs have alleged a 

relationship between those markets.  But whether Plaintiffs are producers of feeder cattle 
is not supported by the facts alleged in the Amended Complaint.  Plaintiffs have not clearly 
established that they are producers of feeder cattle as that term is understood by the 
industry.  There are still too many chains in the link between Plaintiffs and Defendants 
that make Plaintiffs’ alleged injury too remote.  See Southwest Suburban Bd. of Realtors, 

Inc. v. Beverly Area Plan. Ass’n, 
830 F.2d 1374, 1379
 (7th Cir. 1987) (“[A]s a general rule 
suppliers of an injured customer may not seek recovery under the antitrust laws because 
their injuries are too ‘indirect, secondary, or remote.’”).  Accordingly, this factor is again 
neutral.                                                                  

         4.   Directness                                                 
    The Court must next consider the directness between the injury and the market 
restraint, which requires consideration of the “chain of causation.”  McDonald, 
722 F.2d at 1374
; AGC, 
459 U.S. at 540
.  The Court previously found this factor weighs against 

antitrust standing because Plaintiffs failed to explain how their decreased profits are 
traceable to the Defendants’ conduct.  In re Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at *6.  Plaintiffs relied on inferences about the market, which the Court found 

to be unsupported by sufficient factual allegations.  
Id.
                 
    Here, Plaintiffs allege they are several steps removed from Defendants’ alleged 
market manipulation, but that the relationship between the feeder cattle and fed cattle 
markets demonstrates a direct chain of causation between Defendants’ conduct and 

Plaintiffs’ harm.  An indirect plaintiff’s injury may be adequately traceable through the 
product distribution chain to show directness.  E.g., In re Cattle and Beef Antitrust Litig., 
No. 19-1129, 
2021 WL 7757881
, at *11 (D. Minn. Sept. 14, 2021); In re Broiler Chicken 
Antitrust Litig., 
290 F. Supp. 3d 772, 814
 (N.D. Ill. 2017).  But Plaintiffs still must establish 
directness that is not “too remote.”  In re Dynamic Random Access Memory Antitrust 
Litig., 
516 F. Supp. 2d 1072, 1092
 (N.D. Cal. 2007).                      

    While  Plaintiffs  have  provided  more  substantial  allegations  regarding  the 
traceability of Defendants’ conduct to the feeder cattle market, the chain of causation 
depends on whether Plaintiffs are producers of feeder cattle.  And, as explained above, 
Plaintiffs have not clearly demonstrated that they are such producers.  Without that 

necessary fact, Plaintiffs’ allegations are largely the same as before.  This factor therefore 
weighs against standing.                                                  
         5.   Speculative Nature of Damages                              
    The fifth factor is the speculative nature of the damages.  McDonald, 
722 F.2d at 1374
.  The Court previously found this factor neutral because even though other factors 
may affect cow-calf prices, similar meat packing antitrust cases have considered the 
speculative nature of damages and determined that there are means and methods for 

economic analysts to pinpoint prices that would have been paid but for the conspiracy.  
In re Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at *7.  Similarly, here, the fact that 
multiple other factors may affect the prices of the cattle Plaintiffs produce in addition to 
Defendants’ conduct is not dispositive.                                   

    Defendants argue that Plaintiffs fail to account for certain complexities inherent in 
the new proposed classes, such as the fact that harm to one sector may benefit another.  
For example, if cow-calf prices drop, cow-calf ranchers are harmed, but backgrounders or 
stockers  could  be  better  off  as  their  input  costs  to  acquire  calves  decreases.    But 
regression analysis may be used to narrow down various supply and demand factors to 
pinpoint the damages exclusively caused by any alleged market manipulation, regardless 

of the complexities that the new proposed classes may bring.  See In re Pork Antitrust 
Litig., 
665 F. Supp. 3d 967
, 991–92 (D. Minn. 2023).  This factor is therefore neutral. 
         6.   Risk of Duplicative Recovery                               
    The  last  factor  is  the  “risk  of  duplicative  recoveries  or  complex  damage 

apportionment.”  McDonald, 
722 F.2d at 1343
.  The Court previously found this factor 
weighed in favor of antitrust standing, unconvinced that it would be difficult for the 
parties to conduct economic analysis to ascertain an appropriate damages amount.  In re 
Cattle and Beef Antitrust Litig., 
2023 WL 5310905
, at *7.  The Court reaches the same 

conclusion here.  Though Defendants argue that the expansion of Plaintiffs to include all 
indirect sellers makes apportionment more complex and creates a risk of duplicative 
recoveries, economic analyses are capable of ascertaining Plaintiffs’ injuries to avoid 

duplicative recovery.  Therefore, this factor continues to favor antitrust standing.  
                          *    *    *                                    
    Weighing the six AGC factors, the Court finds that Plaintiffs failed to establish 
antitrust standing under AGC.  Because Plaintiffs have not clearly demonstrated that they 

are producers of feeder cattle as understood by the CME Feeder Cattle Index and beef 
production  industry  at  large,  the  Amended  Complaint’s  allegations  regarding  the 
relationship  between  the  fed  cattle  and  the  feeder  cattle  markets  do  not  support 
Plaintiffs’ antitrust standing.  Without more substantial allegations that Plaintiffs are 
producers of feeder cattle, they have not plausibly alleged a causal relationship between 
Defendants’ conduct  and their injury, or that their injury and damages are directly 

traceable to Defendants’ conduct.                                         
    Because Plaintiffs have not established antitrust standing, the Court will dismiss 
Plaintiffs’ Sherman Act, PSA, and state antitrust and consumer protection claims in the 
states that apply AGC.  See 
id.
 at *7 n.5 (listing states).  The Court will also dismiss the only 

remaining  state  antitrust  law  claim  that  does  not  apply  AGC,  which  arises  under 
Minnesota  law.    Even  though  Minnesota  does  not  explicitly  apply  AGC,  it  similarly 
considers proximate causation and directness, which Plaintiffs failed to establish.  See id. 

at *7.                                                                    
    B.   Remaining State Law Claims                                      
    The only remaining claims are Plaintiffs’ consumer protection claims arising under 
Florida and Colorado law, which the Court previously dismissed for lack of proximate 

causation or insufficient pleading of specific harm.  Id. at *9–10.  Because Plaintiffs have 
again failed to establish proximate causation, the Court will dismiss the Florida consumer 
protection claim.  Defendants argue that Plaintiffs’ Colorado consumer protection claim 
fails  because  Plaintiffs  failed  to  allege  that  they  were  injured  by  Defendants’ 

misrepresentations, as required by Colorado law.  See id. at *9.  Though Plaintiffs allege 
they were unable to discern how Defendants’ misrepresentations specifically injured 
them because of Defendants’ fraudulent concealment, the Court previously found such 
these allegations were insufficient.  See id. at *9.  Thus, Plaintiffs have again failed to 
demonstrate how Defendants’ misrepresentations specifically injured Plaintiffs.  The 
Court will therefore dismiss Plaintiffs’ Florida and Colorado consumer protection claims.   

                          CONCLUSION                                     
    The  Court  will  dismiss  Plaintiffs’  Sherman  Act,  PSA,  and  state  antitrust  and 
consumer  protection  claims  for  lack  of  antitrust  standing  under  AGC.    Though  the 
Amended Complaint alleges a relationship between the prices and markets of feeder 

cattle and fed cattle, Plaintiffs have not clearly established that they are producers of 
feeder cattle, so these new allegations are insufficient to establish proximate causation 
and directness.  The Court will also dismiss the remaining state law claims arising under 
Minnesota, Colorado, and Florida laws.                                    

ORDER

    Based on the foregoing, and all the files, records, and proceedings herein, IT IS 
HEREBY ORDERED that:                                                      
    1.  Defendants’ Motion to Dismiss the Amended Specht Complaint [Docket No. 

      453] is GRANTED; and                                               
    2.  Plaintiffs’  Amended  Complaint  [Docket  No.  371]  is  DISMISSED  without 
      prejudice.                                                         
     LET JUDGMENT BE ENTERED ACCORDINGLY. 

DATED:  May 24, 2024                              Otay    | table 
at Minneapolis, Minnesota.                         JOHN R. TUNHEIM 
                                            United States District Judge 

                                    -18- 

Reference

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