RELEVANT GEOGRAPHIC MARKET. Currently, the main interstate pipeline that can deliver gas into North Carolina is Transcontinental Gas Pipe Line Company, LLC’s (“Transco’s”) natural gas transmission system. Transco’s transmission system extends from Texas, Louisiana, Mississippi, Alabama, Georgia, South Carolina, North Carolina, Virginia, Maryland, Pennsylvania, New Jersey and New York.7 As shown in Figure 1, Transco classifies the portion of its pipeline system that goes through North Carolina as Zone 5 (“Transco Zone 5”). Transco Zone 5 contains delivery points in North Carolina, as well as South Carolina and Virginia.
RELEVANT GEOGRAPHIC MARKET. North America The Complaint alleges that the relevant geographic market is no smaller than the United States and Canada (‘‘North America’’).4 Newsprint can be transported within the United States 2 There are two primary newsprint basis weights, 30 pound (48.8 gsm) and 27.7 pound (45 gsm), the lighter of which has a higher yield. The differences between the two weights are not material to product market definition because prices for each basis weight track each other, newspaper publishers can use either weight in their presses, and newsprint manufacturers can produce either weight on the same newsprint machines without incurring switching costs. and Canada at a sufficiently low cost and in such a timely and reliable manner that an attempt to increase price in any smaller region of the United States or North America would prove unprofitable. In the event of such an attempted price increase, customers could readily and economically shift their purchases to newsprint producers throughout North America. In addition, national newspaper buying groups, which account for over 70 percent of all newsprint purchases throughout the United States, create a North American pricing structure. Price differences across regions within the United States have been small and short-lived, as supply has shifted rapidly to restore parity marketwide. The Complaint also alleges that the relevant geographic market is no broader than North America. Newsprint xxxxx located in Canada and the United States account for approximately 98 percent of North American newsprint consumption. Transportation costs of importing newsprint are high, and customers are concerned about the reliability of foreign newsprint supply. Consequently, a small but significant increase in the price of newsprint will not likely cause customers to purchase sufficient volumes of additional newsprint from outside North America to make such a price increase unprofitable. Accordingly, North America is a relevant geographic market.
