The Supreme Court decision in Bell Atlantic v. Twombly, 550 U.S. 544 (2007) created some debate whether the decision applied to non-antitrust cases. The Supreme Court’s recent decision in Ashcroft v. Iqbal, No. 07-1015 (U.S. May 18, 2009) applying Twombly to a non-antitrust case makes clear that Twombly has broad reach. A copy of the decision is here.







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