Major League Baseball Properties, Inc. v. Salvino, Inc.

Every MLB team granted an exclusive license to Major League Baseball Properties (MLBP) (plaintiff) to control use of team names, logos, and other intellectual property, and MLBP sued Salvino, Inc. (defendant) for trademark infringement after it produced team-logo stuffed animals without a license. Salvino counterclaimed that MLBP's centralized licensing scheme violated the Sherman Antitrust Act by fixing prices and limiting output, but presented no supporting studies, while MLBP's expert testified the teams functioned as a joint venture whose intellectual property value depended on the league's overall popularity, and that the relevant product market included licenses from all sports leagues and possibly all entertainment properties. The district court granted MLBP summary judgment, and Salvino appealed.