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Keywords

plaintiffdefendantappealmotiontrustintellectual propertyclass actionantitrustmotion to dismiss

defendantpleamotiontrustantitrustmotion to dismiss

Related Cases

Dang v. San Francisco Forty Niners, 964 F.Supp.2d 1097, 2013-2 Trade Cases P 78,472

Facts

Consumer Patrick Dang filed a putative class action against the NFL and its member clubs, alleging anticompetitive behavior related to the licensing of NFL intellectual property for apparel. He claimed that an exclusive licensing agreement with Reebok led to inflated prices for NFL-branded apparel, which he purchased. The defendants moved to dismiss the case, arguing that Dang failed to establish a relevant market and lacked antitrust standing. The court found that Dang sufficiently alleged the existence of a relevant market and antitrust standing.

Issue

Did the consumer adequately allege the existence of a relevant product market and antitrust standing under California's Cartwright Act and the Sherman Act?

Rule

To establish a valid antitrust claim under California's Cartwright Act or the Sherman Act, a plaintiff must demonstrate that the defendant possesses market power within a legally cognizable relevant market. The relevant market must be a product market composed of products that have reasonable interchangeability for their intended purposes. Additionally, antitrust standing requires the plaintiff to show injury in their business or property due to the defendant's unlawful conduct.

Analysis

The court analyzed whether Dang's allegations of a relevant market were sufficient. It noted that he claimed a market consisting of NFL-branded apparel, where individual teams competed against each other. The court found that this market was not a single-brand market, as it included multiple competing brands. Furthermore, the court determined that Dang's injury from purchasing overpriced apparel was directly linked to the alleged anticompetitive conduct, satisfying the requirements for antitrust standing.

The court must accept as true all 'well-pleaded factual allegations.' Ashcroft v. Iqbal, 556 U.S. 662, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009). However, 'courts are not bound to accept as true a legal conclusion couched as a factual allegation.' Twombly, 550 U.S. at 555, 127 S.Ct. 1955.

Conclusion

The court denied the defendants' motion to dismiss, concluding that the consumer adequately alleged both the existence of a relevant market and antitrust standing.

For the reasons explained below, Defendants' Motion to Dismiss is DENIED.

Who won?

The consumer, Patrick Dang, prevailed in this motion to dismiss as the court found his allegations sufficient to establish a relevant market and antitrust standing. The court recognized that the consumer's claims were based on the competitive dynamics among NFL teams and the unique appeal of NFL-branded apparel, which distinguished it from other apparel markets. This ruling allowed the case to proceed, affirming the consumer's right to challenge the alleged anticompetitive practices.

The court found that Dang sufficiently alleged the existence of a relevant market and antitrust standing, allowing his claims to proceed against the defendants.

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