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Restraining trade is not defined by market share. It has nothing to do with monopoly.  It is when someone owns something, (the Dealers owning their data) they may choose to give it away, grant access to it or sell it to whomever, whenever, and for how ever much they decide.  Reynolds is clearly restraining trade (between the Dealership and the Vendor) by imposing a fee on the vendors for access to something they do not own and or shutting down access that the Dealer has granted.