Section 1 of the Sherman Antitrust Act (15 U.S.C. §1) provides in pertinent part: To state a claim under Section 1, a plaintiff must allege facts that, if true, will prove: (1) the existence of a conspiracy, (2) intention on the part of the co-conspirators to restrain trade, and (3) actual injury to competition. To state injury to competition, plaintiff must allege conduct that “actually causes injury to competition, beyond the impact on the claimant.” Concerted action between co-conspirators to eliminate competitive bidding for a contract is an actionable harm to competition.