Ryko Mfg. Co. v. Eden Services, 823 F.2d 1215, 1235 (8th Cir.1987)). In Ryko, the Eighth Circuit Court of Appeals asserted that a higher standard of proof of “substantial foreclosure” is required “[wjhere the exclusive dealing restraint operates at the distributor level, rather than at the consumer level.” Ryko, 823 F.2d at 1235. There is no Supreme Court or Ninth Circuit precedent that adopts this rule. Tampa, Jefferson, and Twin City all call for individualized examination of an alleged substantial foreclosure. See Tampa, 365 U.S. at 329, 81 S.Ct. at 629 (listing several factors to consider in evaluating “substantiality”); Jefferson, 466 U.S. at 29, 104 S.Ct. at 1567 (calling for “inquiry into actual effect of the exclusive contract on competition”); Twin City, 676 F.2d at 1302 (<HOLDING>). These cases do not suggest that a different
holding that there must be a causal connection between the alleged antitrust violation and the antitrust injury for there to be antitrust standing holding that evidence of five prior antitrust actions brought against the defendants was irrelevant on issue of defendants motive to conspire and noting that simply because the defendants were named in past antitrust cases involving similar allegations does not make it more probable that the defendants had a motive to carry out their conspiracy holding that a prior settlement of an antitrust conspiracy case and the resulting judgment dismissing the suit with prejudice could not have res judicata effect in a later suit against additional parties in which the plaintiffs alleged claims based on new types of antitrust violations that were not contemplated by the earlier settlement when it would have the effect of conferring on defendants partial immunity from civil liability for distinct future antitrust violations holding that proof of relevant market is essential under  2 holding that a defendants antitrust liability depends on the overall effects of a defendants conduct in the relevant market