Philadelphia Taxi Association, Inc. v. Uber Technologies, Inc.

886 F.3d 332 (3rd Cir. 2018)


From March of 2005 to October of 2014, taxicabs operating in Philadelphia were required to have a medallion and a certificate of public convenience, issued by the Philadelphia Parking Authority (PPA). Once medallion-holders comply with the obligatory standards for taxicabs, they may obtain a certificate of public convenience. Those standards, which provide for safety and uniformity among taxicabs, require vehicles to be insured and in proper condition, and mandate that drivers are paid the prevailing minimum wage, are proficient in English, and have the appropriate drivers' licenses. In 2005, a medallion was worth only $65,000. In October of 2014, there were approximately 500 taxicab companies in Philadelphia. Together, 7,000 drivers held 1610 medallions, each valued at an average of $545,000. Uber (D) began operating without securing medallions or certificates of public convenience for its vehicles. D allowed a book by application on a mobile phone. D does not own or assume legal responsibility for the vehicles or their operation, nor does it hire the drivers as its employees. D did not pay fines to the PPA or comply with its regulations when it first entered the Philadelphia taxi market, as is otherwise required for medallion taxicabs. Ps maintain that this rendered D's operation illegal, and enabled the company to cut operating costs considerably. Pennsylvania state legislature passed a law approving D's operation in Philadelphia, under the authority of the PPA. D is a Transportation Network Companies (TNC). The law also exempts TNCs from disclosing the number of drivers or vehicles operating in the city and allows TNCs to set their own fares, unlike medallion taxicab companies, which comply with established rates, minimum wages, and have a limited number of vehicles and medallions operating at once in Philadelphia. Before the law, nearly 1200 medallion taxicab drivers left their respective companies and began to drive for D. Simultaneously, medallion taxi rides reduced by about 30 percent, and Ps experienced a 30 percent decrease in earnings. The value of each medallion dropped significantly, to approximately $80,000 in November of 2016. Fifteen percent of medallions have been confiscated by the lenders due to default by drivers. Ps alleged three counts: attempted monopolization under Section 2 of the Sherman Act, tortious interference with contract, and unfair competition under Pennsylvania law. D moved to dismiss the Complaint. D moved to dismiss an Amended Complaint. The District Court granted the dismissal, without prejudice. The District Court concluded that these harms are not the type of injuries that antitrust laws were intended to prevent, and thus do not establish antitrust standing. Ps filed a second amended complaint and it too was dismissed. It held that Ps pled no antitrust injury sufficient for antitrust standing. P appealed.