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.