In US Horticultural Supply Inc. v. Scotts Co., the Third Circuit affirmed an order granting summary judgment to The Scotts Company in a suit under Section 1 of the Sherman Act brought by its former distributor, US Horticultural Supply. The Court found that US Horticultural Supply had failed to establish the relevant competitive market. The Third Circuit required evidence of product interchangeability and cross-elasticity of demand to prove the relevant product market and evidence of buyer behaviour to prove the relevant geographic markets.