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Keywords

contractlawsuitplaintiffdefendantmotiontrustcopyrightclass actionantitrustcivil proceduremotion to dismiss

plaintiffdefendantmotiontrustwillantitrustmotion to dismiss

Related Cases

Washington v. National Football League, 880 F.Supp.2d 1004, 2012-1 Trade Cases P 77,926, 103 U.S.P.Q.2d 1856

Facts

Former professional football players filed a class action lawsuit against the National Football League (NFL) and its teams, alleging violations of the Sherman Act by monopolizing the market for game footage. The players contended that the NFL's refusal to grant them rights to game films and images from their playing days constituted illegal restraint of trade. The defendants moved to dismiss the case, arguing that the complaint failed to state a valid claim under antitrust laws. The court was tasked with determining whether the allegations were sufficient to survive a motion to dismiss.

Complaint alleging that professional football league, its teams, and other defendants monopolized the market for former players' likenesses by not allowing them the rights to game films and images from the games in which they played, failed to state a claim for concerted action in violation of the Sherman Act.

Issue

Did the plaintiffs adequately state a claim for violation of the Sherman Act against the NFL and its teams?

Rule

For a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), the court must accept all factual allegations in the complaint as true and construe them in the light most favorable to the plaintiff. A complaint must contain sufficient factual matter to state a claim that is plausible on its face. The Sherman Act prohibits contracts, combinations, or conspiracies in restraint of trade or commerce.

For purposes of a motion to dismiss for failure to state a claim, the district court takes all facts alleged in the complaint as true. Fed.Rules Civ.Proc.Rule 12(b)(6), 28 U.S.C.A.

Analysis

The court analyzed whether the plaintiffs' allegations constituted a plausible claim under the Sherman Act. It noted that the NFL owned the game footage collectively with the teams, and any concerted action to restrain trade was necessary for marketing the product. The court found that the plaintiffs failed to establish any illegal concerted action, as the restraints were a result of the NFL's ownership of the copyright in the footage. The court concluded that the plaintiffs' claims were more appropriately categorized as royalty disputes rather than antitrust violations.

The court must construe the factual allegations in the complaint and reasonable inferences arising from the complaint favorably to the plaintiff and will grant a motion to dismiss only if it appears beyond doubt that the plaintiff can prove no set of facts which would entitle him to relief.

Conclusion

The court granted the defendants' motion to dismiss, concluding that the plaintiffs failed to state a claim for violation of the Sherman Act.

The Complaint is therefore dismissed with prejudice.

Who won?

The defendants, including the NFL and its teams, prevailed in this case as the court found that the plaintiffs did not adequately allege a violation of the Sherman Act. The court reasoned that the NFL's ownership of the game footage and the necessary cooperation among teams to market the product negated the plaintiffs' claims of illegal restraint of trade. The court emphasized that the issues raised by the plaintiffs were more aligned with royalty disputes rather than antitrust claims, leading to the dismissal of the complaint with prejudice.

The court found that the plaintiffs failed to plausibly allege any antitrust violation from Defendants' conduct.

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Keywords

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Richardson v. Southeastern Conference, 612 F.Supp.3d 753, 412 Ed. Law Rep. 616

Kentucky Speedway, LLC v. National Ass’n of Stock Car Auto Racing, Inc., 588 F.3d 908, 2010-1 Trade Cases P 76,875

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Philadelphia Ball Club v. Lajoie, 202 Pa. 210, 51 A. 973, 58 L.R.A. 227, 90 Am.St.Rep. 276