Football teams that need to cooperate are not trapped by antitrust law. "[T]he special characteristics of this industry may provide a justification" for many kinds of agreements. The fact that NFL teams share an interest in making the entire league successful and profitable, and that they must cooperate in the production and scheduling of games, provides a perfectly sensible justification for making a host of collective decisions. But the conduct at issue in this case is still concerted activity under the Sherman Act that is subject to s. 1 analysis.

The NFL and its 32 member teams teams reached an agreement with Reebok [corporate website] to license and sell consumer headwear and clothing with the respective teams' logos and not to grant licenses to Reebok's competitors for 10 years. The antitrust suit was brought by American Needle [corporate website], which argued that the contract violated the Sherman Act.