The California Supreme Court unanimously concludes there's no pass-through defense. Which seems entirely right. That's what we do in the federal system, and it's certainly what the pro-antitrust litigation California legislature intended when it passed the relevant amendments. Yes, that rule makes damage assessments somewhat difficult, since we may be punishing a defendant twice: first by allowing direct purchasers to sue, with no pass-on defense, and then also allowing indirect purchasers to sue. But the problem isn't insurmountable, and in any event, that's what the Legislature probably wanted.
So California's a good place to bring state antitrust claims. No shocker there.