American Needle, Inc. v. National Football League
United States Supreme Court
560 U.S. 183 (2010)
Relevant factsFree
NFL teams, through their jointly-owned licensing entity NFLP, jointly agreed to grant Reebok an exclusive apparel license rather than the multiple nonexclusive licenses (including one to American Needle, plaintiff) previously granted; American Needle sued the NFL and NFLP (defendants) under §§ 1 and 2 of the Sherman Act after losing its license, and the lower courts held the NFL and NFLP functioned as a single entity incapable of conspiring under § 1.
IssueFree
Whether, regardless of the legal structure of an entity or set of entities, any contract, combination, or conspiracy useful to the entity may violate § 1 of the Sherman Act if the agreement deprives the marketplace of independent decision-making.
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