Laumann v. National Hockey League
United States District Court for the Southern District of New York
907 F. Supp. 2d 465 (2012)
Each team in the National Hockey League (NHL) (defendant) and Major League Baseball (MLB) (defendant) owned the initial rights to telecast its games. Most games were telecast pursuant to agreements between teams and regional sports networks (RSNs) (defendants). The RSNs then sold the telecasts to consumers (plaintiffs) through multichannel video programming distributors (MVPDs) such as Comcast and DirecTV (defendants). MVPDs telecast NHL and MLB games to only those consumers that were within an RSN’s designated service area. In other words, through a standard MVPD package, a consumer could watch only the games of his or her local, in-market team. Games of other out-of-market teams were blacked out. However, consumers could also purchase a national package telecasting all out-of-market games. This was an all-or-nothing package in that a consumer could not choose one out-of-market game or team, but was required to purchase all out-of-market games. In-market games were not telecast as part of this package, meaning that the only way for a consumer to view an in-market game was via a subscription to an MVPD. The plaintiffs brought an antitrust suit against the defendants alleging that the agreements harmed competition in violation of the Sherman Antitrust Act. The defendants jointly filed a motion to dismiss.
Rule of Law
Holding and Reasoning (Scheindlin, J.)
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