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National Basketball Association v. Sports Team Analysis and Tracking Systems (STATS) and Motorola (Sportstrax)

United States Court of Appeals for the Second Circuit
105 F.3d 841 (1997)


Facts

Developed by Motorola (defendant), SportsTrax was a handheld pager which displayed updated statistical information from professional sporting events. Sports Team Analysis and Tracking Systems (STATS) (defendant) supplied the game data information that was transmitted from SportsTrax. Major League Baseball granted a license to Motorola and STATS to transmit updated data from baseball games in progress. In 1994, Motorola and STATS wanted to expand into the professional basketball market. However, talks with the National Basketball Association (NBA) (plaintiff) did not materialize and, instead, Motorola and STATS decided to generate and transmit NBA statistics by themselves and without a license from the league. After the SportsTrax devices began transmitting NBA game data for the 1995-96 season, the NBA brought suit against Motorola and STATS (collectively “defendants”) alleging violations of a host of federal copyright and trademark laws as well as New York’s misappropriation law. The district court found for the NBA and enjoined the defendants from transmitting statistical data related to NBA games. The defendants appealed.

Rule of Law

Issue

Holding and Reasoning (Winter, J.)

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