Docket nos. 08-661 | Citations 560 U.S. 183 (more) | |
Full case name American Needle, Inc., Petitioner v. National Football League, et al. Majority Stevens, joined by unanimous | ||
American Needle, Inc. v. National Football League, 560 U.S. 183 (2010), was a United States Supreme Court case regarding the ability of teams in the National Football League to conspire for purposes of a violation of §1 of the Sherman Act.
Contents
Background
The alleged conspiracy involved the formation of the National Football League Properties (NFLP), an entity responsible for licensing NFL intellectual property and formed in 1963. Before that date the NFL teams marketed their IP rights individually.
Between 1963 and 2000, the NFLP granted nonexclusive licenses to a various suppliers to sell and manufacture apparel bearing the team insignias. Petitioner, American Needle, Inc., was one of those license holders. In December 2000, the teams voted to authorize the NFLP to grant exclusive licenses from then on. The NFLP granted a 10-year exclusive license to Reebok to manufacture and sell trademarked headwear bearing team insignia of all 32 teams. After that the NFLP declined to renew American Needle's nonexclusive license.
Opinion of the Court
The Court held that NFL teams are distinct economic actors with separate economic interests that are capable of conspiring under §1 of the Sherman Act.