In American Needle, Inc. v. Nat'l Football League, U.S. 130 S.Ct. 2201, 2206-07, L.Ed.2d (2010), a professional football league, its teams, and a corporate entity the teams formed to manage their intellectual property were sued by one of their licensees for allegedly violating 1 of the Sherman Act, 15 U.S.C. 1. 130 S.Ct. at 2206. The defendants asserted that their licensing activities were beyond the coverage of 1 of the Sherman Act because they were collectively acting as a single entity. The Supreme Court disagreed, stating that "the mere fact that the teams operate jointly in some sense does not mean that they are immune" from the antitrust laws. Id. at 2214.