Championsworld, LLC v. United States Soccer Federation, Inc.
890 F. Supp. 2d 912
N.D. Ill.2012Background
- ChampionsWorld formed in 2000 to promote international soccer matches in the U.S., contracting with USSF for sanctioning and fees.
- USSF is FIFA’s U.S. member governing authority; SUM and MLS are closely linked entities involved in promotions and marketing.
- Plaintiff challenged USSF’s sanctioning fees and bonds as discriminatory and unsupported by FIFA rules; USSF defended authority under FIFA statutes.
- Arbitration occurred before FIFA’s PSC with CAS, culminating in rulings that USSF could sanction and charge fees for FIFA-affiliated matches and notify FIFA of delinquencies.
- This federal case seeks to confirm the CAS award under the New York Convention; ChampionsWorld sought to challenge authority and remedies in court.
- The court confirmed the arbitral award, denied partial summary judgment on several claims, and granted in part Defendants’ motions, including exclusion of Rodney Fort’s testimony and summary judgment on the antitrust claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the CAS award falls within the New York Convention | ChampionsWorld argues the award is domestic and not sufficiently foreign-connected. | USSF contends the award arises from a foreign, commercial relationship and seat of arbitration abroad, within the Convention. | Convention applies; award is enforceable. |
| Standing to pursue RICO and antitrust claims | Plaintiff asserts broader standing to challenge sanctions on all FIFA-related matches. | Defendant argues standing is limited to FIFA-affiliated matches Promoted by ChampionsWorld. | RICO standing limited to FIFA-affiliated matches; antitrust standing discusses market power but not dispositive here. |
| USSF’s authority to sanction and charge fees | USSF lacked authority to sanction non-members and to impose certain fees; authority premised on Ted Stevens Act inapplicable to professional soccer. | FIFA statutes and roles granted USSF authority to sanction and levy fees for FIFA-related matches. | Under CAS rulings and related authority, USSF had sanctioning authority for FIFA-affiliated matches. |
| Admissibility of expert Rodney Fort’s market definition | Fort’s market definition is valid and supports a broader antitrust challenge. | Fort’s market definition is unreliable, lacks proper economic testing, and is not admissible. | Fort’s market-definition testimony excluded; insufficient basis for antitrust liability. |
| Summary judgment on antitrust and related claims | Antitrust claim should survive given flawed deployments of FIFA-based authority. | Without a cognizable market definition and with CAS-based preclusion, antitrust liability cannot stand. | Antitrust claim granted summary judgment for defendants. |
Key Cases Cited
- Brown Shoe Co. v. United States, 370 U.S. 294 (1962) (Brown Shoe factors for market definition.)
- Reifert v. S. Cent. Wisc. MLS Corp., 450 F.3d 312 (7th Cir. 2006) (economic analysis required for market power; Brown Shoe factors.)
- Fraser v. Major League Soccer, L.L.C., 284 F.3d 47 (1st Cir. 2002) (context on MLS/MLS-related corporate structures in soccer.)
- Kentucky Speedway, LLC v. National Ass’n of Stock Car Auto Racing, Inc., 588 F.3d 908 (6th Cir. 2009) (subsidiary circuit discussion on market definition in sports.)
- Chicago Prof'l Sports Ltd. P'ship v. Nat'l Basketball Ass'n, 961 F.2d 667 (7th Cir. 1992) (market and competition considerations in sports leagues.)