Law360, New York ( August 26, 2016, 11:34 AM EDT) -- In a painstaking dissection of the "inextricably intertwined" standard often used by courts to determine whether plaintiffs can show they suffered "antitrust injury" if they neither purchased from, nor competed with, a defendant, the Second Circuit recently held that consumers that are used as tools to manipulate a defendant's market can pursue damage claims suffered from manipulation in that market. However, the Second Circuit went on to hold, consumers that suffered the consequences of a defendant's unlawful conduct in another market cannot because their injuries were not the "very means" by which defendants corrupted the market in which the defendants participated. In re Aluminum Warehousing Antitrust Litig., No. 14-3574(L), 2016 WL 4191132, at *8 (2d. Cir., Aug. 9, 2016)....