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31 U. Miami Bus. L. Rev. 90 (2022-2023)
Epic Games, Inc. v. Apple, Inc: An Epic Opinion for Software Developers

handle is hein.journals/umblr31 and id is 98 raw text is: Epic Games, Inc. v. Apple, Inc.: An Epic Opinion for Software Developers Gabriella V. Coffieldal Aside from Google Play, Apple's App Store is where the majority of apps are downloaded from across the world. Recently, Apple has faced scrutiny for its management of the App Store and the control Apple has over the market due to the lack of competition. Additionally, developers have criticized the 30% fee Apple charges them for in-app purchases. The recent ruling by the Northern District of California in Epic Games, Inc. v. Apple, Inc., 559 F. Supp. 3d 898 (N.D. Cal. 2021) addressed this issue and issued an injunction allowing the possibility for developers to direct consumers to external links to subscribe or make purchases which could allow the developers to circumvent Apple's high commission rates. In Epic Games, Inc. v. Apple, Inc., the court held Apple was not an antitrust monopolist in the market of mobile gaming transactions under the Sherman Act; however, Apple's anti- steering restrictions were held to be anticompetitive and unlawful under the unfair prong of California's Unfair Competition Law. This Comment analyzes how the Northern District of California correctly applied prior law in its holding that Epic Games failed to satisfy the rule of reason test to prove Apple's app distribution restrictions were anticompetitive effects that were harmful to consumers and unlawful under §1 of the Sherman Act. While Apple's app distribution restrictions did have anticompetitive effects, Apple was able to validate the anticompetitive effects with security, interbrand competition, and intellectual property as al Juris Doctor Candidate at the University of Miami School of Law, Class of 2023; Executive Editor of the University of Miami Business Law Review, Vol. 31. Special thanks to Dean Michael Chiorazzi for his support in creating this Comment. 90

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