Netafim Irrigation, Inc. v. Jain Irrigation, Inc.

CourtDistrict Court, E.D. California
DecidedJuly 15, 2022
Docket1:21-cv-00540
StatusUnknown

This text of Netafim Irrigation, Inc. v. Jain Irrigation, Inc. (Netafim Irrigation, Inc. v. Jain Irrigation, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Netafim Irrigation, Inc. v. Jain Irrigation, Inc., (E.D. Cal. 2022).

Opinion

1 2 UNITED STATES DISTRICT COURT 3 EASTERN DISTRICT OF CALIFORNIA 4 5 NETAFIM IRRIGATION, INC., CASE NO. 1:21-cv-00540-AWI-EPG

6 Plaintiff, ORDER ON DEFENDANTS’ MOTION 7 v. TO DISMISS PLAINTIFF’S FIRST AMENDED COMPLAINT 8 JAIN IRRIGATION, INC., JAIN DISTRIBUTION HOLDINGS, INC., 9 IRRIGATION DESIGN & (Doc. No. 34) CONSTRUCTION, LLC, and AGRI- 10 VALLEY IRRIGATION, LLC,

11 Defendants

12 13 14 This case involves an alleged anticompetitive acquisition involving competitors in the 15 micro-irrigation industry. Presently before the Court is Defendants Jain Irrigation, Inc., Jain 16 Distribution Holdings, Inc., Irrigation Design & Construction, LLC, and Agri-Valley Irrigation, 17 LLC’s Motion to Dismiss Plaintiff Netafim Irrigation, Inc.’s First Amended Complaint. Doc. No. 18 34. The First Amended Complaint (“FAC”) asserts causes of action under Section 1 of the 19 Sherman Act, Section 7 of the Clayton Act, and the Lanham Act. Doc. No. 25. Having 20 considered the parties’ submissions, the Court will grant in part and deny in part Defendants’ 21 Motion. 22 BACKGROUND1 23 Plaintiff and Defendants are involved in the micro-irrigation industry in Central California. 24 Doc. No. 25, ¶ 2. Micro-irrigation is a comparatively cost-effective and sustainable form of 25 irrigation that delivers water and nutrients directly to the root systems of crops. Id., ¶ 17. The 26

27 1 This section summarizes allegations set forth in the FAC. See Doc. No. 25. Additionally, the Court takes judicial notice of the exhibit (Doc. No. 36-2) submitted with Defendants’ motion to dismiss. See BMA LLC v. HDR Global 28 Trading Ltd., 2021 U.S. Dist. LEXIS 169327, *8 n.4 (N.D. Cal. Sep. 7, 2021); Kim v. Shellpoint Partners, LLC, 2016 1 micro-irrigation industry has three levels: (1) manufacturers that produce equipment for micro- 2 irrigation systems; (2) local design firms that customize, install, and maintain micro-irrigation 3 systems for growers; and (3) growers that purchase and use micro-irrigation systems on their 4 farms. Id., ¶ 18. Growers do not purchase micro-irrigation equipment directly from 5 manufacturers, but instead purchase it through local design firms. Id., ¶ 20. The services and 6 expertise of local design firms are crucial to growers because improper irrigation risks harm to a 7 grower’s crop and livelihood and because micro-irrigation systems require substantial investments 8 in equipment of as much as $1,000-$3,000 per acre. Id. 9 Manufacturers compete to supply micro-irrigation equipment through local design firms. 10 Id., ¶ 19. To ensure that design firms are knowledgeable about the manufacturers’ product lines 11 and prices, manufacturers invest time and money in their relationships with the design firms. Id., 12 ¶ 21. Manufacturers also often provide design firms with non-public pricing and individualized 13 bids on large projects. Id. Notwithstanding these relationships, design firms have historically 14 worked with multiple manufacturers to offer growers a wide selection of micro-irrigation 15 equipment so that growers have a choice between competitive products and can select between 16 them based on price and quality. Id., ¶ 22. This approach fosters competition between 17 manufacturers to offer lower prices and higher quality so that design firms would carry their 18 products and recommend them to growers. Id. 19 Plaintiff and the Jain entities are the two largest manufacturers in Central California. Id., ¶ 20 19. Other competing manufacturers include Rivulis, Eurodrip, Toro, Irritec, and Rain Bird. Id. In 21 2016, Plaintiff had approximately $65 million in sales in Central California. Id. Jain, on the other 22 hand, had approximately $25 million in Central Valley sales in 2016. Id. Rivulis and Eurodrip, 23 who was later acquired by Rivulis in 2017, had combined sales of approximately $20 million in 24 Central California in 2016. Id. Toro, Irritec, and Rain Bird each had Central California sales in 25 2016 of approximately $15 million, $6 million, and $5 million, respectively. Id. 26 On May 16, 2017, Defendant Jain Distribution Holdings, Inc.—a sister company of 27 Defendant Jain Irrigation, Inc.—acquired an 80% interest in Defendant Irrigation Design & 28 Construction, LLC (“IDC”) and an 80% interest in Defendant Agri-Valley Irrigation, LLC 1 (“AVI”).2 Id. Before these acquisitions, IDC and AVI were the largest local design firms in a 2 number of markets in Central California. Id., ¶¶ 23, 24. IDC had stores farther north in Central 3 California, such as in Dixon and Stockton, while AVI had stores farther south, such as in Fresno, 4 Visalia, and Bakersfield. Id., ¶ 38. They had overlapping stores in the central part of the valley, 5 such as in Dos Palos-Firebaugh. Id. Based on Plaintiff’s experiences in and understanding of the 6 micro-irrigation industry in Central California, IDC and AVI had the following estimated 7 combined market shares in 2016 in the following geographic markets: 8 • Dos Palos-Firebaugh:3 Approximately 60-65% 9 • Patterson-Newman:4 Approximately 45% 10 • Stockton:5 Approximately 50% 11 Id., ¶ 25. 12 Pre-acquisition, IDC and AVI carried and sold equipment from many manufacturers, 13 including those of Plaintiff, Jain, Rivulis, Eurodrip, Toro, Irritec, and Rain Bird. Id., ¶¶ 26, 27. In 14 2016, IDC was Plaintiff’s largest dealer in Central California, selling over $7.2 million of 15 Plaintiff’s products. Id., ¶ 29. AVI was also a large Netafim dealer, selling over $1.4 million in 16 Plaintiff’s products. Id. Netafim made substantial sales through IDC and AVI in previous years, 17 and had invested in expanding its relationship with IDC and AVI. Id. IDC and AVI were also 18

19 2 While the FAC explains that Jain Distribution is the holding company for IDC and AVI— and that both Jain Distribution and Jain Irrigation are wholly owned subsidiaries of Jain Irrigation Systems Limited, “an Indian multi- national conglomerate” that has not itself been sued in this action—the FAC refers to Jain Irrigation and Jain 20 Distribution collectively as “Jain.” See Doc. No. 25, ¶ 7. Defendants do not dispute this naming convention in their briefing. Thus, for purposes of this order, the Court will adopt that practice as well. 21

3 The FAC describes the Dos Palos-Firebaugh market as “no broader than the region bounded by Interstate 5 on the 22 west, up to the Los Banos Waterfowl Management Area, San Luis National Wildlife Refuge, and Merced National Wildlife Refuge on the northwest, over to Chowchilla on the northeast, and down to Mendota on the south.” See Doc. 23 No. 25, ¶ 67. Netafim had sales of about $3.1 million through IDC and AVI in 2016 and made about 50% of its sales through them in this market. Id., ¶ 68. 24 4 The FAC describes the Patterson-Newman market as “no broader than the region bounded by Interstate 5 on the 25 west, up to Tracy on the northwest, to Waterford on the northeast, to Livingston on the east, and down toward Los Banos on the south.” See Doc. No. 25, ¶ 69. Netafim had total sales of about $2 million through IDC in 2016 and 26 made about 99% of its sales in this market through IDC. Id., ¶ 70.

27 5 The FAC describes the Stockton market as “no broader than the area extending to Collierville in the north, the Sierra Nevada foothills and Escalon-Bellota Road on the east, the Stanislaus River on the southeast, and the California Delta 28 on the west.” See Doc. No. 25, ¶ 71. Netafim had total sales of about $2.8 million through IDC in 2016 and made 1 large dealers in 2016 for other manufacturers including Rivulis, Eurodrip, Toro, Irritec, and Rain 2 Bird. Id., ¶ 30. 3 Post-acquisition, Plaintiff terminated its relationships with IDC and AVI because its 4 products would allegedly be disfavored to Jain’s products and because Plaintiff wished to avoid 5 providing Jain with access to its competitively sensitive pricing and product information. Id., ¶ 6 33.

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Netafim Irrigation, Inc. v. Jain Irrigation, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/netafim-irrigation-inc-v-jain-irrigation-inc-caed-2022.