American Needle, Inc. v. National Football League case brief

American Needle, Inc. v. National Football League case brief summary
130 S.Ct. 2201 (2010)

CASE SYNOPSIS

Petitioner former licensee sued respondents, including a professional football league, its teams, and a licensor, alleging antitrust violations under 15 U.S.C.S. §§ 1 and 2 of the Sherman Act. The district court granted summary judgment for respondents on the § 1 claim, and the United States Court of Appeals for the Seventh Circuit affirmed. The United States Supreme Court granted certiorari.

CASE FACTS

The teams formed the licensor to license their intellectual property. The licensee alleged that the agreements among respondents violated § 1. The district court and the Seventh Circuit found that § 1 did not apply because the league, the teams, and the licensor acted as a single entity with regard to the licensing of intellectual property.

DISCUSSION

• The Supreme Court held that the licensing activities constituted concerted action that was not categorically beyond the coverage of § 1, and the legality of that action had to be judged under the rule of reason. 
• The relevant inquiry was whether there was a "contract, combination, or conspiracy" among separate economic actors pursuing separate economic interests. 
• If an agreement joined together independent centers of decision making, the entities were capable of conspiring under § 1. 
• The teams competed in the market for intellectual property, and decisions to collectively license their separately owned trademarks deprived the marketplace of independent centers of decision making. 
• The licensor's decisions constituted concerted action, as the licensor acted as an instrumentality of the teams in making licensing decisions.

CONCLUSION

In a unanimous decision, the Court reversed the Seventh Circuit's judgment and remanded the case for further proceedings.

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