The Ninth Circuit Court of Appeals vacated a district court's partial summary judgment in favor of Japanese manufacturer NHK Spring Co., Ltd. and its affiliates, allowing Seagate Technology LLC to proceed with antitrust claims under the Sherman Act. The decision, filed Jan. 8, 2026, reverses a lower court ruling that had dismissed the case based on jurisdictional grounds.
The case centers on allegations that NHK Spring engaged in unlawful price-fixing of suspension assemblies, critical components used in hard drives manufactured by Seagate. The plaintiffs include Seagate Technology LLC, an American company, along with Seagate Technology (Thailand) Ltd., Seagate Singapore International Headquarters Pte. Ltd., and Seagate Technology International.
Defendants in the case include NHK Spring Co., Ltd., NHK International Corporation, NHK Spring (Thailand) Co., Ltd., NAT Peripheral (Dong Guan) Co., Ltd., and NAT Peripheral (H.K.) Co., Ltd. The litigation originated as a multidistrict litigation proceeding in the U.S. District Court for the Northern District of California under Judge Maxine M. Chesney.
The antitrust claims stem from a separate federal criminal proceeding in which NHK pleaded guilty to conspiring with competitors to fix prices of suspension assemblies sold in the United States and elsewhere globally. These suspension assemblies are essential components that were incorporated into Seagate's hard drive products.
The district court had initially granted partial summary judgment in favor of the NHK defendants, ruling that the Sherman Act did not extend to cover foreign injuries suffered by Seagate's international entities. According to court documents, Seagate's foreign subsidiaries purchased the allegedly price-fixed suspension assemblies outside the United States, and these components were then incorporated into Seagate's hard drives.
The Ninth Circuit panel, consisting of Circuit Judges Consuelo M. Callahan and Kenneth K. Lee, along with District Judge Scott H. Rash of the District of Arizona sitting by designation, disagreed with the lower court's analysis. Judge Lee authored the opinion for the three-judge panel.
The appeals court held that Seagate had adequately alleged violations of federal antitrust law, despite the international nature of some of the alleged conduct and injuries. The decision represents a victory for Seagate in its effort to hold NHK Spring accountable for the price-fixing conspiracy that had already resulted in criminal convictions.
This case highlights the complex jurisdictional issues that arise in international antitrust litigation, particularly when American companies and their foreign subsidiaries seek to recover damages for price-fixing conspiracies that affect global markets. The Sherman Act's reach in cases involving foreign commerce has been the subject of extensive litigation and evolving legal precedent.
The price-fixing conspiracy involved suspension assemblies, specialized components that are crucial to hard drive functionality. These assemblies help position read-write heads precisely over spinning disk platters, making them essential to data storage device performance. The alleged conspiracy would have artificially inflated prices for these components across global markets.
NHK Spring's guilty plea in the criminal proceeding provided strong evidence of the price-fixing conspiracy's existence. Criminal antitrust prosecutions by the Department of Justice often precede civil litigation, as the criminal convictions can serve as powerful evidence in subsequent civil cases seeking monetary damages.
The remand to the district court means the case will proceed to further litigation phases, potentially including discovery, motion practice, and possibly trial. Seagate will now have the opportunity to develop its claims and seek damages for the alleged antitrust violations.
For Seagate, the decision removes a significant procedural hurdle that had threatened to end the case before reaching the merits. The company can now pursue recovery for damages allegedly caused by the price-fixing conspiracy across its global operations.
The case also demonstrates the challenges facing companies seeking to combat international price-fixing schemes. While the conduct may affect global markets, jurisdictional requirements can create barriers to recovery, particularly when foreign subsidiaries are involved.
The Ninth Circuit's decision was argued and submitted June 6, 2025, in San Francisco, California. The court's opinion provides guidance for other companies facing similar jurisdictional challenges in international antitrust cases.
Moving forward, the district court will need to address the substantive aspects of Seagate's antitrust claims, including the scope of damages and the application of antitrust law to the international price-fixing conspiracy. The case remains pending as the litigation returns to the trial court level for further proceedings.