In a recent decision in Ashcroft v. Iqbal, 556 U.S. ____, Slip Op., issued on May 18, 2009, the Supreme Court extended the reach of its decision in Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), to a non-antitrust case and expressly affirmed that because Twombly construed Rule 8 of the Federal Rules of Civil Procedure, rather than any antitrust rules, its reasoning was applicable to all civil actions in the federal courts.
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