As Director and Levi (1956) observed, in the first twenty years of the Sherman Act, antitrust lawsuits frequently targeted businesses that were of enormous relative size gained through mergers and acquisitions and that overtly engaged in practices regarded as abusive. The quintessential example of this trend is the classic Standard Oil case. Standard Oil—a gigantic corporation—formed as a result of a number of mergers and acquisitions, and in this 1911 case, the United States government charged Standard Oil not only for being an unlawful monopoly that needed to be broken up into thirty-four independent companies but also for engaging in abusive practices, such as predatory pricing.

Philip Mirowski & Dieter Plehwe (eds.), The Road from Mont Pèlerin, loc. 1136