Gold Medal LLC v. USA Track & Field, No. 16-35488 (9th Cir. 2018)
Annotate this CaseThe Ninth Circuit affirmed the district court's dismissal of an action alleging that USATF and the Olympics Committee engaged in an anticompetitive conspiracy in violation of antitrust law when it imposed advertising restrictions during the Olympic Trials for track and field athletes. The panel held that the Olympics Committee and USATF were entitled to implied antitrust immunity on the basis that their advertising restrictions were integral to performance of their duties under the Ted Stevens Olympic and Amateur Sports Act. The panel noted that an injunction preventing enforcement of the advertisement regulation would open the floodgates to potential advertisers, some of which might enhance the Olympic brand and some of which might devalue the Olympic brand.
Court Description: Antitrust. The panel affirmed the district court’s dismissal of a complaint alleging that USA Track & Field and the United States Olympics Committee engaged in an anticompetitive conspiracy in violation of antitrust law by imposing advertising restrictions during the Olympic Trials for track and field athletes. Following the analysis of the Tenth and Eleventh Circuits, and distinguishing a decision of the Fifth Circuit, the panel held that the Olympics Committee and USATF were entitled to implied antitrust immunity on the basis that their advertising restrictions were integral to performance of their duties under the Ted Stevens Olympic and Amateur Sports Act. Concurring in the result, Judge Nguyen disagreed with the majority’s conclusion that the defendants were immune from the antitrust claim alleged in the complaint. Judge Nguyen wrote that the complaint nevertheless failed to state a claim under § 1 of the Sherman Act because, even if the plaintiff could allege a plausible conspiracy and a viable product market, it did not allege that the defendants received any economic benefit. GOLD MEDAL LLC V. USA TRACK & FIELD 3
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