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These physical tie-in cases, involving the simultaneous marketing of two or more new, physically compatible, complementary products, have all presented similar fact patterns. The defendant manufacturer possessed substantial market power in a primary goods market, and faced competition in a second market for parts, accessories, or other goods physically complementary to the primary product. The defendant introduced a new primary product for which it produced the only physically compatible complementary products. As with any new product introduction, the defendant achieved a temporary monopoly in this new primary product. Because competitors' products in the secondary market were physically incompatible with the new primary product, the defendant also temporarily increased its market power in the secondary market.3 The plaintiffs, who in all cases were competitors in the secondary market, attacked these physical tie-ins on one or both of two grounds. They first contended that the physical tie-in constituted a tying arrangement violative of Section 1 of the Sherman Act 4 and Section 3 of the

An Economic and Legal Analysis of Physical Tie-Ins