Harold Vogel, an experienced gem appraiser, is a member of the American Society of Appraisers. Mr. Vogels

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Harold Vogel, an experienced gem appraiser, is a member of the American Society of Appraisers. Mr. Vogel’s fee for his work is based on a percentage of the value of the appraised item. The society expelled him under the authority of a bylaw that provides, “It is unprofessional and unethical for the appraiser to do work for a fixed percentage of the amount of value.” Mr. Vogel brought suit under Section 1 of the Sherman Act, alleging that his expulsion was a boycott and that he no longer had referrals from the society. Mr. Vogel also claims the bylaw is a means of fixing prices. Is he right? [Harold Vogel v American Society of Appraisers, 744 F.2d 598 (7th Cir. 1984)]

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