Plaintiffs Call for Remedies Against Apple's Unlawful Monopolization in Smartphone Market

X. Request for Relief

232. To remedy these illegal acts, Plaintiffs request that the Court:

1. Adjudge and decree that Apple has acted unlawfully to monopolize, or, in the alternative, attempt to monopolize, the smartphone market in the United States in violation of Section 2 of the Sherman Act, 15 U.S.C. § 2;

   
   

2. Adjudge and decree that Apple has acted unlawfully to monopolize, or, in the alternative, attempt to monopolize, the performance smartphone market in the United States in violation of Section 2 of the Sherman Act, 15 U.S.C. § 2, the New Jersey Antitrust Act, N.J.S.A. 56:9-1 to -19, Wisconsin’s Antitrust Act, Wis. Stat. Ch. § 133.03 et seq.;

   
   

3. Enter relief as needed to cure any anticompetitive harm;

   
   

4. Enjoin Apple from continuing to engage in the anticompetitive practices described herein and from engaging in any other practices with same purpose or effect as the challenged practices, including but not limited to:

   
   

a. preventing Apple from using its control of app distribution to undermine cross-platform technologies such as super apps and cloud streaming apps, among others;

b. preventing Apple from using private APIs to undermine cross platform technologies like messaging, smartwatches, and digital wallets, among others; and

c. preventing Apple from using the terms and conditions of its contracts with developers, accessory makers, consumers, or others to obtain, maintain, extend, or entrench a monopoly.

5. Enter any other preliminary or permanent relief necessary and appropriate to restore competitive conditions in the markets affected by Apple’s unlawful conduct;

6. Enter any additional relief the Court finds just and proper; and

7. Award each Plaintiff, as applicable, an amount equal to its costs, including reasonable attorneys’ fees, incurred in bringing this action.

Dated: March 21, 2024

Respectfully,

FOR PLAINTIFF UNITED STATES OF AMERICA:

FOR PLAINTIFF STATE OF NEW JERSEY:

FOR PLAINTIFF STATE OF ARIZONA:

FOR PLAINTIFF STATE OF CALIFORNIA:

FOR PLAINTIFF STATE THE DISTRICT OF COLUMBIA:

FOR PLAINTIFF STATE THE DISTRICT OF CONNECTICUT:

FOR PLAINTIFF STATE OF MAINE:

FOR PLAINTIFF PEOPLE OF THE STATE OF MICHIGAN:

FOR PLAINTIFF OF STATE OF MINNESOTA:

FOR PLAINTIFF STATE OF NEW HAMPSHIRE:

FOR PLAINTIFF STATE OF NEW YORK:

FOR PLAINTIFF STATE OF NORTH DAKOTA:

FOR PLAINTIFF STATE OF OKLAHOMA:

FOR PLAINTIFF STATE OF OREGON:

FOR PLAINTIFF STATE OF TENNESSEE:

FOR PLAINTIFF STATE OF WISCONSIN:

FOR PLAINTIFF STATE OF VERMONT: