The United States Supreme Court granted certiorari to American Needle, Inc. v. National Football League to determine whether the National Football League could be considered a single entity for purposes of antitrust law, specifically Section 1 of the Sherman Act. A ruling that the National Football League is a single entity—rather than thirty-two separate teams—would mean that the league is completely immune from antitrust laws. This Note examines the split among the federal circuit courts of appeal on this issue and argues for the United States Supreme Court to adopt the approach taken by the majority of federal circuit courts because sports leagues fail to meet the Copperweld requirement of complete "unity of interest" that is necessary for single entity treatment.

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