In the 1954 case of Lawlor et al., Trading as Independent Poster Exchange, v. National Screen Service Corp. et al., the U.S Supreme Court ruled in favor of Independent Poster Exchange (IPE), a small business that rented and sold promotional materials for films to theaters. The court found that National Screen Service Corporation (NSSC) had violated antitrust laws by creating exclusive contracts with major film studios, which effectively monopolized the market for such materials and prevented IPE from competing fairly. NSSC argued that their actions were not illegal because they did not completely exclude IPE from the market; however, this argument was rejected by the court on grounds that even partial restraint of trade is prohibited under antitrust law if it significantly impacts competition.

The dissenting opinion in the Lawlor v. National Screen Service Corp case, delivered by Justice Reed, argued that the majority's decision to allow a retrial was incorrect because there was no evidence of monopolistic practices or intent on part of National Screen Service Corp (NSSC). He contended that NSSC’s contracts with film producers were not exclusive and did not prevent other companies from entering into similar agreements. Furthermore, he stated that these contracts did not limit competition but rather promoted it by allowing NSSC to invest in expensive printing equipment which improved the quality and reduced costs for all customers. The justice also disagreed with the majority's interpretation of patent laws as anti-competitive, arguing they are designed to encourage innovation and should be upheld unless clearly abused. Lastly, he believed this case had been brought forward primarily due to business rivalry rather than genuine concerns about market competition.