In McLafferty v. Deutsche Lufthansa AG et al., Eastern District of Pennsylvania Judge Louis H. Pollack dismissed a putative class action brought by an American who accused four foreign airlines, including Deutsche Lufthansa AG and Air France, of conspiring to fix price of air travel between Europe and Japan. The court ruled that the Foreign Trade Antitrust Improvements Act of 1982 – an amendment to the Sherman Act – excluded the case from the subject matter jurisdiction of the federal courts. In dismissing the complaint, the Court rejected plaintiff’s argument that because she was in the United States at the time the defendants sold her the tickets, the defendants imported ticket-selling services, and held that a ticket to fly between Europe and Japan, even if purchased from, and then delivered to, the United States, does not properly qualify as an import or good, because the ticket has no value apart from the service it entitles its bearer. Therefore, the alleged misconduct involved trade or commerce, other than import trade or import commerce, with foreign nations, and did not have a direct, substantial or reasonably foreseeable anti-competitive effect on U.S. commerce.