American Needle, Inc. v. NFL

In American Needle, Inc. v. NFL, 538 F.3d 736 (7th Cir.2008), rev'd, U.S. 130 S.Ct. 2201, L.Ed.2d 2010 WL 2025207 (U.S. May 24, 2010), the Supreme Court emphasized that "teams that need to cooperate are not trapped by antitrust law," id. at 2215 because "`the special characteristics of this industry may provide a justification' for many kinds of agreements." Id. "When `restraints on competition are essential if the product is to be available at all,' per se rules of illegality are inapplicable, and instead the restraint must be judged according to the flexible Rule of Reason." Id.