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Case: 1:20-cv-07191 Document #: 1 Filed: 12/04/20 Page 1 of 3 PageID #:1
`
`UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
`
`TARGET CORPORATION,
`Plaintiff,
`
`v.
`AGRI STATS, INC., et al.,
`
`Defendants.
`
` Case No.:
`
` Jury Trial Demanded
` (Related to In re Broiler Chicken Antitrust
` Litigation – Case No.: 1:16-cv-08637)
`
`COMPLAINT
`
`1.
`
`Plaintiff Target Corporation (“Target”), is a Minnesota corporation with its
`
`principal place of business in Minneapolis, Minnesota. Target operates approximately 1900 retail
`
`stores throughout the United States and also engages in internet sales via Target.com.
`
`2.
`
`Target is a direct purchaser of Broilers from several producer Defendants, brings
`
`this action under the federal antitrust laws against the Defendants identified below and incorporates
`
`by reference the factual allegations and reservations of rights contained in the Direct Action
`
`Plaintiffs’ Consolidated Complaint and Demand for Jury Trial, filed in In re Broiler Antitrust
`
`Litigation, Civil Action No. 1:16-cv-08637 (ECF 3924; ECF 3922).
`
`3.
`
`Target joins Section II of the Direct Action Plaintiffs’ Consolidated Complaint and
`
`Demand for Jury Trial, adding the following to specify Target’s causes of action and the
`
`Defendants in Target’s action:
`
`

`

`Case: 1:20-cv-07191 Document #: 1 Filed: 12/04/20 Page 2 of 3 PageID #:2
`
`Plaintiff Name
`Target Corporation
`
`Causes of Action
`Count I (Sherman Act Claim for
`all Anticompetitive Conduct);
`Count II (Sherman Act Claim for
`Output Restriction); Count III
`(Sherman Act
`for GA Dock
`Manipulation)
`
`Named Defendants1
`Agri Stats; Amick,
`Case;
`Claxton;
`Fieldale; Foster Farms;
`George’s; Harrison;
`House of Raeford;
`Keystone; Koch; Mar-
`Jac; Mountaire; O.K.
`Foods; Peco; Perdue;
`Pilgrim’s
`Pride;
`Sanderson; Simmons;
`Tyson; Wayne
`
`WHEREFORE, Plaintiff respectfully requests that the Court:
`
`PRAYER FOR RELIEF
`
`A.
`
`B.
`
`Enter joint and several judgments against all Defendants in favor of Plaintiff;
`
`Award Plaintiff treble damages, of an amount to be determined at trial, to the
`
`maximum extent allowed under the federal antitrust laws;
`
`C.
`
`Award Plaintiff post-judgment interest as provided by law, with such interest to be
`
`awarded at the highest legal rate;
`
`D.
`
`Award Plaintiff its attorneys’ fees, litigation expenses, and costs, as provided by
`
`law;
`
`E.
`
`Grant Plaintiff such other and further relief to which Plaintiff is entitled.
`
`JURY DEMAND
`
`Pursuant to Federal Rule of Civil Procedure 38, Plaintiff demands a trial by jury on all of
`
`its claims and issues so triable.
`
`December 3, 2020
`
`
`
`BY:
`
`/s/ Robert M. Burke
` One of Plaintiff’s attorneys
`
`1 The Defendants named in this Complaint include the entire Defendant family of each Defendant
`in this table, identified in Section IV.B. of ECF 3922/ECF 3924.
`2
`
`

`

`Case: 1:20-cv-07191 Document #: 1 Filed: 12/04/20 Page 3 of 3 PageID #:3
`
`Scott E. Gant
`BOIES SCHILLER FLEXNER LLP
`1401 New York Avenue, NW
`Washington, DC 20005
`Telephone: (202) 237-2727
`Fax: (202) 237-6131
`Email: sgant@bsfllp.com
`Attorneys for Plaintiff
`
`Robert M. Burke
`JOHNSON & BELL, LTD.
`33 West Monroe Street - Suite 2700
`Chicago, Illinois 60603
`(312) 372-0770
`(312) 372-9818 (Fax)
`owensk@jbltd.com (Email)
`Local Counsel for Plaintiff
`
`3
`
`

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