American Needle: A New Quick Look for Joint Ventures

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American Needle: A New Quick Look for Joint Ventures

Volume 25 Number 1

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In American Needle, Inc. v. National Football League, the Supreme Court held that the collective decisions of the thirty-two National Football League teams regarding the joint licensing of team intellectual property constituted concerted action subject to scrutiny under Section 1 of the Act. Some view the decision as an unremarkable reaffirmation of the Court’s prior precedent that the rule of reason applies to the operations of joint ventures. A more nuanced reading of the opinion, however, suggests not only some ambiguity with respect to “settled” antitrust law, but also the potential development of new joint venture principles.

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ANTITRUST is the premier magazine devoted exclusively to antitrust. It has a circulation of about 9,000, which goes to all ABA Antitrust Section members in the United States and abroad, and to individual subscribers and libraries.