Court Allows Antitrust Claims Concerning Apple’s iCloud Restrictions to Proceed

Antitrust claims in Gamboa v. Apple have been allowed to proceed in a  California federal court. Peter Angelica of Proskauer explains that Apple’s iCloud storage practices on mobile devices are at issue.

The plaintiffs allege that Apple unlawfully leveraged its control over iOS to restrict third-party cloud storage options, thereby coercing users into adopting iCloud for full-service storage.

The decision to deny Apple’s motion to dismiss signals the courts’ growing willingness to examine “technological tying” as a form of monopolization under the Sherman Act.

The dispute centers on Apple’s restriction of access to certain “restricted files” essential to complete backups for third-party storage providers.

Initially, the court dismissed the plaintiffs’ Sherman Act Section 1 tying claim due to the absence of concerted action or explicit conditioning. However, plaintiffs revised their claims under Section 2 of the Sherman Act, alleging Apple’s unilateral conduct and dominant position effectively forced users into using iCloud.

With that shift in legal theory, the court found that the plaintiffs plausibly alleged anticompetitive conduct and potential monopoly power.

A key issue was market definition. Plaintiffs first proposed a narrow, iCloud-only market, which the court rejected. They then advanced into a broader market, which included iCloud and competitors like Google Drive.

This adjustment, paired with data showing Apple’s overwhelming 96.1% revenue share, supported a viable Section 2 monopolization claim. The court also accepted that local storage was not a substitute at the pleading stage.

Gamboa illustrates the vitality of Section 2, tying claims based on product design, the centrality of market definition, and the power of empirical data in antitrust litigation. Technology companies should reevaluate how design choices could be construed as exclusionary conduct, particularly in platform-restricted ecosystems.