Celonis offers its customers process-mining software to collect and analyze various kinds of enterprise resource planning (ERP) data to help evaluate and improve business process efficiency. Celonis alleges that in 2021 SAP acquired Signavio, a Celonis competitor, and subsequently began imposing restrictions and curtailing technical support for third-party process miners like Celonis to access SAP customer data. In its complaint against SAP in the U.S. District Court for the Northern District of California, Celonis alleged that this conduct violated the Sherman Antitrust Act and California’s Unfair Competition Law. In its October 27, 2025, order, the court granted in part and denied in part SAP’s motion to dismiss Celonis’ amended complaint. The court allowed most of Celonis’ antitrust claims to proceed to discovery, including actual monopolization of a putative “data access” aftermarket, attempted monopolization of the process mining market, and illegal bundling/predatory pricing.
SAP offers a leading ERP software, which many organizations use to power downstream products like Celonis’ process mining tool. ERP applications unify core business functions (e.g., finance, human resources, supply chain) into a single system, while process mining analyzes ERP data to optimize the customer’s business processes.
Celonis’ core theory is that its business depends on reliable access to SAP customers’ ERP data, and that SAP, while custodian of that data, has imposed technical and cost barriers making it unreliable or prohibitively expensive for non-Signavio process miners to operate. These restrictions, Celonis argues, effectively exclude third-party service providers and favor SAP’s own Signavio product. District Judge Vince Chhabria emphasized that the alleged antitrust violation rests on SAP’s restrictions on its customers’ ability to access their own ERP data, and not a “refusal to deal” with Celonis. However, the court also reserved the right to analyze SAP’s conduct under a refusal-to-deal framework, pending evidence produced during discovery.
Celonis claims that access to data within SAP’s ERP constitutes a separate “data access” product market that SAP has monopolized through such restrictions. SAP counters that “data access” is simply a functionality of ERP software, and not a separate product. The court agreed that Celonis adequately alleged that an SAP ERP “data access” aftermarket exists distinct from SAP’s ERP product. Further, Celonis sufficiently pled that SAP’s restrictive access policies could harm competition in both the data access aftermarket and downstream process mining market.
Importantly, while the court found that the SAP ERP “data access” market could exist as a distinct aftermarket based on the allegations of the amended complaint, the court nonetheless noted that it would reserve final determination until after discovery.
Additionally, Celonis made claims for false advertising and tortious interference, which also survived, but claims based on tying and promissory estoppel were dismissed with leave to amend.
Another case pending in the U.S. Court of Appeals for the Ninth Circuit also focuses on data access, albeit using a different theory. In CoStar Group, Inc. v. Commercial Real Estate Exchange, Inc. (CREXi), CREXi alleges that CoStar imposes anticompetitive restrictions on three product markets: commercial real estate listings services, information services, and auction services. Each of these markets serves as a source of commercial real estate broker data controlled by CoStar. The Ninth Circuit reversed the dismissal of CREXi’s antitrust claims because the combination of CoStar’s contract terms and the creation of technical barriers plausibly prevented potential competitors from accessing otherwise publicly available information.
Instead of arguing for monopolization of a “data access” aftermarket in each of the identified product markets, CREXi claims that CoStar’s restrictions on accessibility are evidence of anticompetitive conduct that led to monopolization of each of the underlying product markets. The CREXi case thus highlights additional plausible monopolization theories plaintiffs may raise when locked out of data from an upstream data source.
Fenwick Law Clerk Vaibs Srikaran contributed to this alert.