American Needle vs. The National Football League Properties

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The teams of the NFL established the NFLP or National Football League Properties to “develop, license, and market” the teams' intellectual property in 1963. The organization allowed a certain amount of nonexclusive licenses to a variety of licensees. American Needle was one of the licensees. They made a variety of headwear that displayed the various NFL team logos. The licensing agreement lasted until 2000. The NFL teams sanctioned the NFLP to give Reebok an exclusive license for headwear. With this decision, the NFLP did not renew American Needle’s license or the licenses of any other headwear vendors.
American Needle Inc. filed a suit in an Illinois district court against the NFL, NFLP, NFL teams, and Reebok, claiming that this exclusive license agreement violated Section 1 of the Sherman Act, 15 § U.S.C. 1, which outlaws any “contract, combination . . . or conspiracy, in restraint of trade.” American Needle argued that because individual teams separately own their team logos and trademarks, their collective agreement to authorize NFLP to award the exclusive headwear license to Reebok, was a conspiracy to restrict other vendors' ability to obtain licenses for the teams' intellectual property.
The respondents, NFL, moved for a motion of summary judgment on the Section 1 claim, arguing it was immune from antitrust liability as a single entity. In response, American Needle sought a continuance and asked the U.S. District Court to allow discovery, a motion opposed by the

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