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Law School Case Brief

Rock v. NCAA - 928 F. Supp. 2d 1010 (S.D. Ind. 2013)

Rule:

To survive a motion to dismiss, an alleged product market must bear a rational relation to the methodology courts prescribe to define a market for antitrust purposes—analysis of the interchangeability of use or the cross-elasticity of demand—and it must be plausible. 

Facts:

In July 2012, plaintiffs John Rock, Tim Steward, and Kody Collins filed an antitrust action in federal district court against defendant National Collegiate Athletic Association ("NCAA"), challenging three NCCA bylaws. Two bylaws were at issue in prior litigation, Agnew v. National Collegiate Athletic Association: (1) the prohibition on multi-year athletics-based scholarships, and; (2) the cap on the number and amount of athletics-based scholarships. Third bylaw challenged by plaintiffs prohibited athletics-based scholarships at Division III schools. Plaintiffs argued that these bylaws unlawfully restrained trade among NCAA member institutions for the labor of student-athletes. The NCAA filed a motion to dismiss plaintiffs' action. 

Issue:

Should the court grant the NCAA's motion to dismiss?

Answer:

Yes.

Conclusion:

The granted the motion to dismiss. The court held that dismissal was warranted because plaintiffs' proposed nationwide market for the labor of student athletes was not legally cognizable. To survive a motion to dismiss, an alleged product market must bear a rational relation to the methodology courts prescribe to define a market for antitrust purposes—analysis of the interchangeability of use or the cross-elasticity of demand—and it must be plausible. Plaintiffs made no effort to properly identify the labor market at issue, plead its rough contours, or account for the commercial reality of the transaction, and it was not the court's duty to do so.

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