Eastman Kodak v. Image Technical Services

Businesses buy copiers and microfilm equipment from several brands. Initial purchase prices look competitive. But years of maintenance and proprietary parts may matter more over the machine's life.

Independent service organizations (ISOs) repaired Kodak machines for customers seeking lower labor rates. Kodak allegedly restricted parts access and changed policies to drive ISOs out.

Kodak argued there is only one 'Kodak equipment' market—if equipment sales face rivalry, aftermarket cannot be separate monopoly. The Supreme Court disagreed in a practical way.

Customers who already owned Kodak gear faced switching costs. Even if Kodak competed on first sale, it could exploit locked-in users on service—classic aftermarket monopolization theory.

The 1992 decision revived ISO claims and influenced how courts define product markets when primary and secondary markets interact.

Kodak eventually settled rather than risk trial damages. The case foreshadowed modern repair-rights debates in cars, phones, and farm equipment.

For small repair businesses, Kodak stands for the idea that dominance in parts and service can be unlawful even when the original product seemed competitive.

Aftermarket lock-in affects total cost of ownership.

Market definition can split equipment from service.

Repair competition protects small businesses and consumers.

Kodak monopolized aftermarket for its equipment.

Parts refusals excluded ISOs.

Customers lacked effective alternatives post-purchase.

Kodak cited quality and safety of authorized service.

It argued integrated equipment-service pricing benefited buyers initially.

Right-to-repair fights echo Kodak's aftermarket logic.

Check service and parts costs—not just sticker price.