However, to date, the only explicit consideration of whether umbrella purchasers have a cause of action under the Competition Act is Justice Perell’s analysis in Shah v. LG Chem. In that case, the plaintiff alleged that the defendants’ price fixing of lithium ion batteries led to increased prices across the market. Justice Perell held that it was plain and obvious that umbrella purchasers do not have a cause of action under the Competition Act:
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