Summary Of American Needle Inc Vs Nfl

Title and Citation American Needle Inc. v. National Football League et al., 130 S. Ct. 2201 (2010)

Facts

This case between American Needle Inc. and the National Football League (NFL) focuses on American Needle Inc., a corporation that designed, manufactured, and sold headwear carrying trademarked names and logos of NFL teams, brought an antitrust suit against the NFL, its teams, and the competitor, Reebok. Reebok had exclusive licensing agreement for trademarked headwear and apparel. The case examines whether the NFL’s actions are exempt from antitrust scrutiny under the single entity defense. Founded in 1920, the NFL is an independent association that now includes 32 distinctly owned professional football teams. With the teams, they each have their own name, logo, colors, and owns intellectual property. The 32 teams produce an annual season of football games that ultimately leads to the Super Bowl championship. All of the teams made their own arrangements for licensing their intellectual property and marketing trademark items. In 1963, the teams came to a collective agreement to form the National Football League Properties (NFLP) to license, develop, market the intellectual property of the teams. For years, NFLP has granted nonexclusive licenses to numerous vendors, giving them permission to manufacture and sell

With Justice John Paul Stevens writing for a unanimous Court, it noted that each NFL team is a substantial, independently owned, and independently managed business, whose objectives are not common. The Court reasoned that while the actions of NFL Properties ("NFLP") are not as easily classified as concerted activity, the NFLP's decisions about licensing are a concerted activity and, thus, are covered by Section