Physical Therapy Monopolization Case Survives Motion to Dismiss

In National Athletic Trainers Association v. American Physical Therapy Association, a group of athletic trainers allege that the APTA has employed a number of anticompetitive practices to exclude athletic trainers from the market for manual therapy.  The allegedly exclusionary practices include (1)disparaging athletic trainors by telling the publice and students studying to be physical therapists that only the latter can provide certain types of therapy and (2) instructing physical therapists not to teach athletic trainers how to provide therapy and barring them from APTA conferences.  The APTA sought to dismiss the case for failure to allege adequate product and geographic markets.  The court held that the complaint sufficiently alleged a national manual therapy market for the purposing of surviving a motion to dismiss.

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