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 Antitrust Act.

American Needle v. NFL
Supreme Court of the United States
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

Background

The alleged conspiracy involved the formation of the National Football League Properties (NFLP), an entity responsible for licensing NFL intellectual property (IP) and formed in 1963. Before that date the NFL teams marketed their IP rights individually. Proceeds from NFLP activity were evenly distributed among the teams.[1]

Between 1963 and 2000, the NFLP granted nonexclusive licenses to various suppliers permitting the manufacture and resale of apparel bearing team insignias. The petitioner in this case, American Needle, Inc., was one of those license holders. In December 2000, the teams voted to authorize the NFLP to begin granting exclusive licenses. The NFLP granted a 10-year exclusive license to Reebok to manufacture and sell trademarked headwear bearing team insignia of all 32 teams. At that point, the NFLP did not renew American Needle's nonexclusive license.

Opinion of the Court

In a unanimous decision, 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.[2]

See also

References
  1. "In American Needle v. NFL, Supreme Court Holds That NFL Joint Venture". Pillsbury Law. Retrieved March 23, 2023.
  2. Grady, Mark F. Cases and Materials on Antitrust. UCLA Academic Publishing, Los Angeles, CA. 2011, p. 346-48

Further reading


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