Hobart-Mayfield, Inc. v. NOCSAE, 48 F.4th 656

Mayfield-Mayfield, Inc. makes the S.A.F.E.Clip, a patented aftermarket football-helmet add-on that purports to reduce impact forces; marketed since testing between 2016–2018.
NOCSAE is a nonprofit that publishes voluntary helmet safety standards; certified helmets may bear a NOCSAE logo under license agreements with helmet manufacturers (Riddell, Schutt/Kranos, Xenith).
NOCSAE issued press releases in 2013 and 2018 stating that attaching an add-on creates a new, untested helmet model; 2013 said either helmet or add-on makers could seek recertification, while 2018 limited recertification to helmet manufacturers.
Mayfield alleged those policies, together with helmet manufacturers’ market position, enabled exclusionary conduct: manufacturers could void certifications or warranties to block add-ons, violating Sherman Act §1, Michigan antitrust law, and tortiously interfering with business expectancies.
The district court dismissed Mayfield’s First Amended Complaint under Rule 12(b)(6); the Sixth Circuit reviewed de novo and affirmed dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mayfield plausibly alleged an explicit agreement in violation of §1 (Count I)	NOCSAE licensing agreements plus the 2013/2018 press releases amended those agreements to give helmet makers unilateral power to void certifications, amounting to an agreement to exclude add-ons	Press releases were unilateral NOCSAE statements, not contract modifications or evidence of assent/collusion by helmet makers	Dismissed — allegations do not plausibly show an explicit agreement to restrain trade
Whether Mayfield plausibly alleged a conspiracy via parallel conduct / group boycott (Count II)	Parallel conduct (refusing certification/sales, public statements) plus nine "plus factors" show concerted action to exclude add-ons	Conduct is explained by legitimate safety, warranty, and brand-protection interests; market concentration alone and offered facts are speculative	Dismissed — parallel conduct plus asserted "plus factors" are insufficiently pled and speculative
Whether Mayfield alleged tortious interference (Counts III–VI)	Threats to void warranties or decertify helmets caused potential customers to decline buying S.A.F.E.Clip, harming expected business relationships	Mayfield lacked a reasonable, near-term business expectancy; defendants acted for legitimate safety and reputational reasons, not wrongful malice	Dismissed — no plausible reasonable expectancy and no wrongful or malicious interference shown

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (pleading requires allegations plausibly suggesting agreement, not mere consistency)
Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (legal conclusions not entitled to assumption of truth; plausibility standard)
Watson Carpet & Floor Covering, Inc. v. Mohawk Indus., Inc., 648 F.3d 452 (6th Cir. 2011) (standards for pleading an agreement and circumstantial evidence)
In re Travel Agent Comm’n Antitrust Litig., 583 F.3d 896 (6th Cir. 2009) (use of "plus factors" to infer conspiracy from parallel conduct)
Total Benefits Plan Agency, Inc. v. Anthem Blue Cross & Blue Shield, 552 F.3d 430 (6th Cir. 2008) (elements to plead a rule-of-reason antitrust claim)
NW Wholesale Stationers, Inc. v. Pacific Stationery & Printing Co., 472 U.S. 284 (U.S. 1985) (legitimate rulemaking and enforcement may be lawful even if it limits some competition)
Monsanto Co. v. Spray Rite Serv. Corp., 465 U.S. 752 (U.S. 1984) (simply alleging market structure or oligopoly is insufficient to plead a conspiracy)