Laumann v. National Hockey League

The National Hockey League and Major League Baseball (the leagues) (defendants) comprised individual teams that had broadcast rights to their games in the teams’ home territories. Teams generally contracted with local networks to broadcast games within their local territories. The local networks could not broadcast outside the local territories. However, the local networks were required to allow the leagues to use the local-network broadcasts for broadcasts outside of the local networks’ territories (i.e., nationwide). The local networks sold the programming to distributors, like Comcast and DirectTV (the distributors) (defendants), which would provide the games to consumers within the territories. Some of the games were broadcast nationally, meaning a local territory would see a game that would not normally be broadcast there. The remaining games outside of local territories were available to consumers in those territories only through league packages online. These packages, however, excluded local in-territory games to avoid local networks losing viewers to online viewing through the online packages. A group of consumers (the consumers) (plaintiffs) sued the leagues and the distributors for violating the Sherman Antitrust Act. The leagues and distributors sought dismissal of the claims, which the court denied in part and granted in part. The litigation proceeded, and the leagues and distributors then moved for summary judgment on the other claims. The leagues argued that the various agreements for distributing game broadcasts survived rule of reason analysis as a matter of law.