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Right Field Rooftops, LLC v. Chi. Baseball Holdings, LLC - 87 F. Supp. 3d 874 (N.D. Ill. 2015)

Rule:

The antitrust laws do not create, permit, or imply a cause of action by which to challenge the marketing or sales of the entertainment product of organized professional baseball.

Facts:

Chicago Cubs, a baseball franchise, sued certain various business owners near the franchise's ball field, Wrigley Field, for misappropriating the Cubs’ property rights by selling tickets to patrons to watch Cubs games from the businesses' Rooftops (Rooftops). However, the parties opted to settle their differences by entering into a License Agreement, whereby the Rooftops were permitted to continue their business of wining and dining fans on the rooftops of various buildings surrounding Wrigley Field while viewing the baseball game at a significant distance. Under the Agreement, the Rooftops were required to give the Cubs 17% of their profits and in return, the Cubs agreed not to erect any barricades that would block the long-distance viewing of the game from across the street. There was, however, one clause in the License Agreement that permitted the Cubs to have an expansion of Wrigley Field if that expansion was approved by a governmental authority. Subsequently, the Cubs received a government-issued permit to update the Friendly Confines with electronic signs and video boards that will entirely block the views of the field from the Rooftops clients. The Rooftops filed a complaint, claiming that the Cubs have engaged in anti-competitive practices to put them out of business. The Rooftops contended that the Cubs tried to bully them to price-fix and when they refused, the Cubs retaliated against them by taking steps to erect the massive video board directly in front of their businesses. The Cubs, on the other hand, argued that they enjoy the benefit of being exempt from any antitrust claims.

Issue:

Did the Cubs, a baseball franchise, enjoy the benefit of being exempt from any antitrust claims?

Answer:

Yes.

Conclusion:

The federal district court held that the Cubs was exempt from being accused of antitrust violations under clearly established Supreme Court precedent, and 15 U.S.C.S. § 26b(b)(3), and even if they were not, the Cubs did not engage in anti-competitive behavior. Therefore, surrounding businesses that sought to enjoin the Cubs’ erection of screens and billboards blocking the views of the games from the rooftops of the businesses had no likelihood of success on the merits. Furthermore, the Court averred that even if the baseball exemption to antitrust laws did not apply, the surrounding businesses failed to establish any likelihood of success on the merits of their antitrust claims because they failed to establish a plausible relevant market. The Rooftops also failed to show likelihood of success on their breach claims because license agreement permitted expansion if approved by governmental authorities.

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