The court  rejected petitioner's argument that its efforts to lobby the NFPA were entitled to immunity under Noerr as indirect attempts to influence state and local governments (Pet. App. 17a-19a). Relying on the principle that exemptions from the antitrust laws are to be narrowly construed, the court explained that, while submission of a recommendation to the government is protected by Noerr, antecedent anticompetitive conduct outside the political arena that injures a rival is not entitled to immunity (id. at 17a-18a). The reason, it said, is that the policies underlying the Noerr doctrine do not justify immunizing anticompetitive conduct undertaken to persuade a private organization, because a party can always lobby state and local governments directly

The essence of Noerr is that the Sherman Act does not prohibit private persons from combining to restrain trade by enlisting the instrumentalities of government to impose restraints -- even if the restraints themselves might otherwise be judged unreasonable, and even if the private persons' conduct is of the ugly sort that sometimes occurs in the rough-and-tumble of the political process. The Sherman Act was not intended to trump the right of government to regulate economic behavior, or the right of the citizenry to ask it to do so, whether or not the requests are "reasonable."