United States v. Aluminum Co. of America (Alcoa)

Aluminum went from exotic metal to aircraft and kitchen staple in the early 1900s. Alcoa held key patents and built smelters nationwide, becoming synonymous with the product.

The government sued twice. The first case failed; the second, after World War II, produced Judge Learned Hand's intellectually towering opinion on monopolization law.

Hand agreed Alcoa was an excellent competitor—perhaps too excellent. By expanding capacity to meet all rising demand and maintaining ~90% share for years, Alcoa left no room for rivals to gain footholds.

The opinion controversially suggested monopolization can occur without classic predatory intent: 'Thirty-four years of constantly expanding capacity' can itself exclude competition.

Liability did not immediately break Alcoa apart. Remedy proceedings ordered some divestitures abroad but allowed the integrated firm to continue domestically as competitors finally scaled.

Alcoa became required reading in law schools for Section 2 doctrine—balancing praise for efficiency against fear of perpetual dominance.

Modern tech monopolization cases cite Alcoa when arguing growth investments can foreclose rivals even absent secret cartels.

Defines US monopolization law beyond cartels and fraud.

Capacity expansion can be exclusionary—not only price cuts.

Remedy shortfall shows liability does not always mean breakup.

Alcoa monopolized virgin ingot aluminum.

Exclusive contracts and control of bauxite sources excluded rivals.

Preemptive expansion maintained unlawful dominance.

Alcoa argued superior efficiency and lower consumer prices.

Hand acknowledged no 'evil' intent but still found violation.

Industrial input monopolies affect planes, cars, and packaging costs.

Section 2 remains about market structure, not only bad behavior.