On February 16, 2015, apparel manufacturer American Needle agreed to settle allegations that the National Football League (NFL) and Reebok maintained an exclusive licensing agreement for NFL-branded apparel. In 2000, a joint venture made of up the 32 teams in the NFL, NFL Properties, licensed the rights to each team's trademarks and logos for apparel purposes to Reebok. American Needle, a competing apparel manufacturer, subsequently sued the NFL, NFL Properties and the individual teams, alleging that the licensing agreement restrained trade in the market for NFL-branded hats in violation of Section 1 of the Sherman Act.

In 2010, the US Supreme Court held that NFL Properties' collective licensing was concerted activity, rather than conduct of a single entity, and remanded the case to the US District Court for the Northern District of Illinois for review under the rule of reason (American Needle, Inc. v. Nat'l Football League, 560 U.S. 183 (2010)). In April 2014, the district court held that American Needle presented sufficient evidence of a relevant product market to survive summary judgment, but did not rule on the legality of the agreement (American Needle, Inc. v. New Orleans Louisiana Saints, No. 04-cv-7806, (N.D. Ill. Apr. 4, 2014)).

The details of the settlement are not yet available.

For more information on the American Needle case, see Legal Updates, FTC and DOJ file brief urging Supreme Court to vacate appellate decision in American Needle case and US Supreme Court rules that the NFL is not a single entity for purposes of licensing intellectual property, and Article, American Needle: The Supreme Court Evaluates Antitrust Immunity for Joint Ventures. For more on establishing an exclusive dealing agreement, see Practice Note, Establishing an Agreement under Section 1 of the Sherman Act.