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American Needle, Inc. v. National Football League

United States Supreme Court
560 U.S. 183 (2010)


Facts

In 1963, the teams comprising the National Football League (NFL) (defendant) established the National Football League Properties (NFLP) to collectively license and develop the teams’ intellectual property. In 2000, the NFL teams decided to allow the NFLP to grant exclusive licensing agreements and awarded a 10-year exclusive license to Reebok International Ltd. (Reebok) (defendant) to make and sell headwear featuring the NFL teams’ logos and other intellectual property. American Needle, Inc. (American Needle) (plaintiff) brought a suit against the NFL, claiming that the exclusive licensing agreement between the NFL, the NFL teams, the NFLP, and Reebok violated the antitrust provisions of the Sherman Act. American Needle was a licensee of NFL merchandise prior to the NFL teams’ decision to allow exclusive licensing. In response, the NFL argued that the NFL was incapable of unlawfully conspiring with the NFLP and the NFL teams, because all three parties constituted a single economic entity.

Rule of Law

Issue

Holding and Reasoning (Stevens, J.)

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