The District Court’s Order also highlights, however, that actions not directly tied to contractual performance may continue to be actionable, even if the parties’ actual contract falls outside of the statute of limitations.US Airways v. Sabre Holdings Corp., et al., CA. No. 11-cv-2725 (LGS), ECF No. 1129, at 2 (S.D.N.Y. Mar. 24, 2022) [hereinafter, Order].Id. at 3.Id. 15 USC § 15b. Order at 10 (quoting Zenith Radio Corp. v. Hazeltine Rsch. Inc., 401 US 321, 338 (1971)). Order at 10-11 (quotations omitted, citing Klehr v. A.O. Smith Corp., 521 US 179, 189 (1997) and others).

[1] This resulted in varying limitations periods and forum shopping, which Congress sought to remedy by passing a uniform limitations period in 1955.[2] Specifically, 15 U.S.C. § 15b provides that a federal antitrust claim must be commenced within four years of the date that the cause of action accrued. In order to determine when the four-year limitations period begins to run, a court must first determine when the cause of action accrues.