A U.S. District Court denies three motions for summary judgment for failing to provide sufficient evidence of a relevant market and of manifest anticompetitive effects (American Needle / New Orleans Louisiana Saints)

So Whatever Happened to American Needle?* You remember American Needle, right? It is the 2010 U.S. Supreme Court opinion that explains when the action of a joint venture is the action of a single entity or, instead, the result of an agreement among the joint venture members. Now back on remand in federal district court in Chicago, some recent summary judgment decisions might eventually make the case known for some interesting market definition questions. American Needle was a licensee of NFL Properties (NFL) that challenged under Sherman Act Section 1 the NFL’s decision in 2000 to terminate the licenses of American Needle and others to make NFL-trademarked hats and grant an exclusive license to Reebok. One of the NFL’s defenses was that it was a single entity incapable of reaching the

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Steven J. Cernak, A U.S. District Court denies three motions for summary judgment for failing to provide sufficient evidence of a relevant market and of manifest anticompetitive effects (American Needle / New Orleans Louisiana Saints), 4 April 2014, e-Competitions April 2014, Art. N° 66326

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