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Map of Saint George on The Court also established a partial per se test that condemned most tying arrangements that conditioned the purchase of a desired good on the simultaneous purchase of a second, different good. Though sympathetic toward dealing agreements that required a purchaser to deal exclusively in a particular manufacturer's brand, the Court declared that such agreements were illegal whenever they threatened to foreclose a substantial share of market sales. Partly because the Clayton Antitrust Act's anticompetitive merger clause only applied to stock and not market acquisitions, as well as only to horizontal mergers and not vertical or conglomerate mergers, the Supreme Court's merger decisions in the years after the New Deal were in favor of large acquisitions. This, along with concerns regarding renewed economic concentration, led to the Celler-Kefauver Act of 1950.
This act strengthened the Clayton Antitrust Act, specifically Section 7, by prohibiting one company from securing either stocks or physical assets of another firm when the acquisition would reduce competition. The Act also extended coverage of antitrust laws to all forms of mergers whenever the effect would substantially lessen competition and tend to create a monopoly. By the 1960s, the Supreme Court had reversed its approach to mergers and was even ruling against mergers that might lead to cost savings and lower consumer prices.
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