Rangers v. NHL, And the Single Entity Defense
As previosuly noted, the New York Rangers (i.e., Madison Square Garens, the Rangers’ owner) sued the N.H.L. which was mostly related to control over the Ranger’s website. The ranger’s motion for a preliminary inunction was denied. On Friday, the district court – Judge Preska – granted the NHL’s motion to dismiss as to the parts of the complaint that did not relate to the website dispute, but denied it as to the website (or “New Media”) issue.
The Sports Law Blog provides the analysis of the key antitrust issue:
Judge Preska therefore had to determine if the single entity defense barred MSG’s New Media Strategy Section 1 antitrust claims. Although Judge Preska recognized that “[w]hat is essentially the same [single entity] argument has been rejected in a similar case by the Court of Appeals,” and that “[m]ost other Courts that have taken up the issue have reached the same conclusion,” Judge Preska concluded that the “Court need not—and will not—resolve the question at this juncture [because] the arguments advanced by the NHL in favor of single entity status require examining facts outside the pleadings.” In particular, Judge Preska noted that “there is no evidence in the record on the crucial question of market definition, let alone the inquiry into how the NHL actually operates as an economic actor in that market,” and “therefore the NHL’s arguments in favor of dismissal cannot be resolved at the pleading stage.”
Here is the opinion: madison-square-gardens-l1p-v-national-hockey-league.pdf.
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