Minnesota Law Review
In the past it has been a most common practice of great and powerful combinations engaged in commerce-notably the Standard Oil Co., and the American Tobacco Co., and others of less notoriety, but of great in-fluence-to lower prices of their commodities, oftentimes below the cost of production in certain communities and sections where they had competition, with the intent to destroy and make unprofitable the busi-ness of their competitors, and with the ultimate purpose in view of thereby acquiring a monopoly in the particular locality or section in which the discriminating price is made. Every concern that engages in this evil practice must of necessity recoup its losses in the particular communities or sections where their commodities are sold below cost or without a fair profit by raising the price of this same class of commodities above their fair market value in other sections or communities.
Daniel J. Gifford, Primary Line Injury Under the Robinson-Patman Act: The Development of Standards and Erosion of Enforcement, 64 Minn. L. Rev. 1 (1979), available at http://scholarship.law.umn.edu/faculty_articles/325.