American Needle, Inc. v. National Football League

American Needle v. NFL
Supreme Court of the United States
Argued January 13, 2010 Decided May 24, 2010
Full case name	American Needle, Inc., Petitioner v. National Football League, et al.
Docket no.	08-661
Citations	560 U.S. 183 (more) 130 S. Ct. 2201; 176 L. Ed. 2d 947; 94 U.S.P.Q.2d 1673
Case history
Prior	538 F.3d 736, 88 U.S.P.Q.2d 1358 (7th Cir. 2008)
Holding
The National Football League's licensing of intellectual property in this case constitutes concerted action that is not categorically beyond Section 1 of the Sherman Antitrust Act's coverage. The judgment of the Seventh Circuit is reversed.
Court membership
Chief Justice John Roberts Associate Justices John P. Stevens · Antonin Scalia Anthony Kennedy · Clarence Thomas Ruth Bader Ginsburg · Stephen Breyer Samuel Alito · Sonia Sotomayor
Case opinion
Majority	Stevens, joined by unanimous
Laws applied
Sherman Antitrust Act

American Needle, Inc. v. National Football League, 560 U.S. 183 (2010), was a United States Supreme Court case regarding the ability of teams in the National Football League to conspire for purposes of a violation of §1 of the Sherman Act.

Background[]

The alleged conspiracy involved the formation of the National Football League Properties (NFLP), an entity responsible for licensing NFL intellectual property and formed in 1963. Before that date the NFL teams marketed their IP rights individually.

Between 1963 and 2000, the NFLP granted nonexclusive licenses to a various suppliers to sell and manufacture apparel bearing the team insignias. Petitioner, American Needle, Inc., was one of those license holders. In December 2000, the teams voted to authorize the NFLP to grant exclusive licenses from then on. The NFLP granted a 10-year exclusive license to Reebok to manufacture and sell trademarked headwear bearing team insignia of all 32 teams. After that the NFLP declined to renew American Needle's nonexclusive license.

Opinion of the Court[]

The Court held that NFL teams are distinct economic actors with separate economic interests that are capable of conspiring under §1 of the Sherman Act.^[1]

See also[]

• Mid-South Grizzlies v. National Football League
• Radovich v. National Football League
• List of United States Supreme Court cases, volume 560

References[]

Further reading[]

• He, Yifei American Needle Upon Remand, https://ssrn.com/abstract=2520044

External links[]

• Text of American Needle, Inc. v. National Football League, 560 U.S. 183 (2010) is available from: Google Scholar  Justia  Oyez (oral argument audio)  Supreme Court (slip opinion) 

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