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American Needle, Inc. v. National Football League

American Needle, Inc. v. National Football League, 560 U.S. 183 (2010), was a United States Supreme Court case regarding the ability of teams in the National Football League to conspire for purposes of a violation of §1 of the Sherman Act.

American Needle v. NFL
Seal of the United States Supreme Court
Argued January 13, 2010
Decided May 24, 2010
Full case nameAmerican Needle, Inc., Petitioner v. National Football League, et al.
Docket no.08-661
Citations560 U.S. 183 (more)
130 S. Ct. 2201; 176 L. Ed. 2d 947; 94 U.S.P.Q.2d 1673
Case history
Prior538 F.3d 736, 88 U.S.P.Q.2d 1358 (7th Cir. 2008)
Holding
The National Football League's licensing of intellectual property in this case constitutes concerted action that is not categorically beyond Section 1 of the Sherman Antitrust Act's coverage. The judgment of the Seventh Circuit is reversed.
Court membership
Chief Justice
John Roberts
Associate Justices
John P. Stevens · Antonin Scalia
Anthony Kennedy · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Samuel Alito · Sonia Sotomayor
Case opinion
MajorityStevens, joined by unanimous
Laws applied
Sherman Antitrust Act

Contents

BackgroundEdit

The alleged conspiracy involved the formation of the National Football League Properties (NFLP), an entity responsible for licensing NFL intellectual property and formed in 1963. Before that date the NFL teams marketed their IP rights individually.

Between 1963 and 2000, the NFLP granted nonexclusive licenses to a various suppliers to sell and manufacture apparel bearing the team insignias. Petitioner, American Needle, Inc., was one of those license holders. In December 2000, the teams voted to authorize the NFLP to grant exclusive licenses from then on. The NFLP granted a 10-year exclusive license to Reebok to manufacture and sell trademarked headwear bearing team insignia of all 32 teams. After that the NFLP declined to renew American Needle's nonexclusive license.

Opinion of the CourtEdit

The Court held that NFL teams are distinct economic actors with separate economic interests that are capable of conspiring under §1 of the Sherman Act.[1]

See alsoEdit

ReferencesEdit

  1. ^ Grady, Mark F. Cases and Materials on Antitrust. UCLA Academic Publishing, Los Angeles, CA. 2011, p. 346-48

Further readingEdit

External linksEdit