<p>In another legal development that concerns the U.S. wireless industry, a U.S. district court judge dismissed for lack of evidence a series of antitrust class-action suits that accused the four national wireless carriers of conspiring to raise text message rates in tandem over a two-year period. The class-action complaints were filed with the U.S. District Court for the Northern District of Illinois in the wake of a 2008 letter from Senate Antitrust Subcommittee Chairman Herb Kohl (D-WI) to Verizon Wireless, AT&amp;T, Sprint Nextel and T-Mobile USA that questioned identical text message rate increases among all four carriers from 10-cents to 20-cents per message between 2006 and 2008. Although the plaintiffs argued that the rate increases were indicative of an illegal price-fixing conspiracy involving the four carriers, Judge Matthew Kennelly granted the defendants&rsquo; motion for dismissal, declaring that &ldquo;taken together, plaintiffs&rsquo; factual allegations do not give rise to more than the &lsquo;mere possibility&rsquo; of an agreement, which is insufficient to state a claim for conspiracy.&rdquo; Specifically, Kennelly noted that the plaintiffs &ldquo;make no allegations about particular meetings at which they contend any of the defendants reached an agreement,&rdquo; as he observed that the plaintiffs &ldquo;offer no statements by any of the defendants suggesting the presence of an agreement.&rdquo; While acknowledging that the carriers&rsquo; behavior &ldquo;possibly could result from an agreement,&rdquo; Kennelly determined that the complainants fell short in proving &ldquo;that defendants&rsquo; conduct was anything other than merely parallel conduct that could just as well be independent action.&rdquo;</p>