Philadelphia World Hockey Club v. Philadelphia Hockey Club
United States District Court for the Eastern District of Pennsylvania
351 F.Supp. 462 (1972)
The fledgling World Hockey Association (plaintiff), including the Philadelphia World Hockey Club, tried to attract talent by luring players away from NHL teams like the Philadelphia Hockey Club (defendant), whose standard player contracts included a perpetually renewable reserve clause also used across NHL-affiliated minor leagues. The WHL sought a federal injunction against the NHL and its teams pursuing state-court injunctions that had blocked more than 60 NHL players from moving to the WHL, and the district court granted the injunction, prompting the NHL's challenge.
Whether, to violate Sherman Act Section 2, an entity must possess monopoly power in the relevant market coupled with intent for the willful acquisition or maintenance of that power.