Leo Zinn (plaintiff) served as the agent for Lemar Parrish (defendant), a professional football cornerback for the NFL’s Cincinnati Bengals. Under the terms of their annually-renewable contract, Zinn received a 10 percent commission in return for using “reasonable efforts” in negotiating job contracts on behalf of Parrish, advising him on business investments, securing professional tax advice at no additional cost, and obtaining endorsement contracts. Additionally, Zinn sought to obtain Parrish off-season employment. At the end of the 1973 NFL football season, the World Football League (WFL) recruited Parrish to play for the league. Zinn had several initial conversations with the WFL’s Jacksonville Sharks, but eventually decided not to pursue the Sharks as a viable option for Parrish’s employment. Instead, Zinn negotiated a four-year deal with the Bengals, who were aware of Zinn’s conversations with the Sharks, for $250,000 as well as a $30,000 signing bonus. After signing the four contracts with the Bengals, Parrish telephoned Zinn and told him that he “no longer needed his services” and refused to pay Zinn any commission on the contracts. Zinn brought suit against Parrish for breach of contract. The district court held for Parrish and Zinn appealed.