Last week the United States District Court for the Western District of Washington dismissed two of the four counts—including an antitrust claim—brought by a disgruntled franchisee in Danforth & Associates, Inc. v. Coldwell Banker Real Estate, LLC, 2011 U.S. Dist. LEXIS 10882 (W.D. Wash. Feb. 3, 2011). In addition to dismissing a claim for breach of contract, the court made a brief and specific ruling that a claim under Section 1 of the Sherman Antitrust Act cannot be based on an alleged conspiracy between a franchisor and a franchisee. For this reason, the court ruled that the plaintiff-franchisee could not seek relief under a theory that its franchisor had conspired with another franchisee to favor that franchisee over the plaintiff.