Article:
John E. Lopatka & Andrew N. Kleit, The Mystery of Lorain Journal and the Quest for Foreclosure in Antitrust, 73 TEXAS L. REV. 1255 (1995).
 

Abstract:
Firms historically have been held to violate the antitrust laws by acting in such a way that their rivals were foreclosed from some trading relationship. Beginning in the 1970s, economists and legal scholars have debated whether predatory strategies are profitable. While instances of real foreclosure have been identified, economists have argued that the predatory strategies resulting in foreclosure were either efficiency-increasing behavior or simple horizontal monopolies. Thus, economists have refuted all of the famous foreclosure cases of the last 100 years, save one, Lorain Journal Co. v. United States, which has been recognized as the rare instance of real predation.

Lorain Journal is conventionally explained as an attempt by a newspaper to drive a radio station out of business and to recoup any loses sustained in the process with monopoly profits earned after the radio station was closed. Lopatka and Kleit argue that this conventional interpretation is incorrect because the newspaper could not have expected to force the radio station out of business. The authors offer a tying explanation, based on the idea that radio advertising was a good substitute for newspaper advertising for some purposes, but not others. Alternatively, they suggest the newspaper may have been motivated by the idiosyncratic utility the publisher derived from hurting a competitor. The authors contend that whichever explanation is accepted, neither Lorain Journal, nor any other antitrust case, supports a hostile antitrust policy to purported foreclosure.