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American Needle, Inc. v. National Football League

560 U.S. 183, 130 S.Ct. 2201, 176 L.Ed.2d 947 (2010)

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American Needle, Inc. v. National Football League

United States Supreme Court

560 U.S. 183, 130 S.Ct. 2201, 176 L.Ed.2d 947 (2010)

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Facts

Prior to 1963, the various teams within the National Football League (NFL) (defendant) made their own arrangements for licensing and marketing trademarked merchandise items such as caps and jerseys featuring the team’s logo and mark. In 1963, the teams formed the National Football League Properties (NFLP) to coordinate the development and licensing of the teams’ merchandise. Between 1963 and 2000, the NFLP granted nonexclusive licenses to a number of vendors, including American Needle, Inc. (plaintiff), to manufacture and sell apparel featuring team logos. In December 2000, however, the NFLP granted a 10-year exclusive license to Reebok to manufacture and sell trademarked gear for all 32 teams. American Needle’s license was not renewed. American Needle filed suit against the NFL alleging violations of §§ 1 and 2 of the Sherman Act. Specifically, American Needle claimed that the NFL and the NFLP conspired to restrict the distribution of the teams’ intellectual property rights. The district court granted the NFL’s motion for summary judgment. The Court of Appeals for the Seventh Circuit affirmed. The U.S. Supreme Court granted certiorari to review.

Rule of Law

Issue

Holding and Reasoning (Stevens, J.)

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