Pocahontas Coal Company filed suit against a number of other companies engaged in the mining and production of coal in West Virginia. Pocahontas alleged that the defendants were involved in a conspiracy to control the production and pricing of coal. One of Pocahontas's specific claims was that the defendants had violated § 8 of the Clayton Act by "deputizing" various persons to sit on the boards of competing subsidiaries. The defendants moved for summary judgment, noting that Pocahontas's complaint contained no factual allegations that any of the defendants were competitors, failed to name any of the alleged "deputies," and was ambiguous because it alleged that certain persons were "officers and/or directors" of competing companies. The trial court offered Pocahontas the opportunity to clarify the complaint by bringing forth additional information on these points. Did the court properly grant the defendants summary judgment when Pocahontas declined to do so?
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