University of Miami Law Review


The courts have developed two tests for determining the proper judicial districts in which corporate defendants in antitrust suits may be sued under section 12 of the Clayton Act. The United States Court of Appeals for the Seventh Circuit applied the less restrictive test in holding that the parent corporation was "transacting business" in the local district through the activities of its subsidiary. The author agrees with the court's application of a totality-of-circumstances analysis in finding that venue was proper but criticizes the court for not having taken the opportunity to inter the more restrictive test.