‘American Needle 9 – National Football League 0’: Background and Implications of the Supreme Court’s Unanimous Denial of the NFL’s Attempt at Single Entity Status in Sports Law, Antitrust, IP and Labor Law

Abstract

American Needle manufactured and sold hats for the National Football League (“NFL”) until December of 2000 when the NFL signed an exclusive ten-year licensing agreement with Reebok. As a result, American Needle’s licensing agreement was not renewed, prompting American Needle to file suit against the NFL under the Sherman Act in the Northern District of Illinois. American Needle alleged that the licensing agreement with Reebok was an unlawful restraint on trade and thus a violation of Section 1 of the Sherman Act in that each of the 32 NFL teams had conspired to freeze it and other competitors out of the market for NFL merchandise.