Section Four of the Clayton Act,2 the treble-damage action provision of the federal antitrust laws, was intended to foster and encourage competition by allowing private enforcement of the antitrust laws. The ever-present threat of a private action for treble-damages serves as a deterrent to anyone contemplating business activities in violation of the antitrust laws and offers the possibility of compensation to victims injured by anti-competitive activities.3 The Supreme Court's decision in illinois Brick Co. v. lllinois4 defined the reach of the trebledamage provision by holding that only direct purchasers of illegally monopolized products or services have standing to sue under Section Four of the Clayton Act

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