The United States Court of Appeals for the First Circuit affirmed summary judgment for two insurance companies on an antitrust claim filed by a group of podiatrists. The court found that physicians serving on the insurers' boards of directors did not pursue interests independent of the corporations. This precluded a finding of concerted action against the podiatrists, which is a necessary element of a Section 1 claim under the Sherman Act. The court rejected the podiatrists' claim that the physician board members effectively controlled the insurers where the physicians constituted a board minority and lacked the ability to control either the corporations or their respective benefit policies. The court also dismissed the podiatrists' misrepresentation claim under the Lanham Act because the podiatrists failed to allege misrepresentation through the use of a particular advertising or promotional medium, a requirement under the Act.