Paul, Weiss has successfully secured the dismissal of an antitrust class action lawsuit against the National Hockey League (NHL). The case was filed by two former junior hockey league players and was dismissed by the U.S. District Court for the Western District of Washington due to lack of personal jurisdiction.
The lawsuit initially began in February 2024 when the players accused both the NHL and the Canadian Hockey League (CHL) of forming a cartel that restricted the market for hockey services, allegedly violating Section 1 of the Sherman Act. The case was first filed in New York, where it was dismissed against CHL defendants due to lack of personal jurisdiction. Subsequently, plaintiffs voluntarily dropped their claims against the NHL but re-filed a similar suit in Washington.
The NHL’s motion to dismiss argued several points: lack of personal jurisdiction under Rule 12(b)(2), absence of Article III standing and antitrust standing by plaintiffs, and that their claims were barred by non-statutory labor exemption to antitrust laws as well as by the Foreign Trade Antitrust Improvements Act (FTAIA).
U.S. District Judge Tana Lin ruled in favor of dismissing on personal jurisdiction grounds. She stated that plaintiffs could not establish jurisdiction over the NHL through either the Clayton Act or Washington’s long-arm statute. Judge Lin explained that since “the NHL is ‘an unincorporated joint venture association,’ not a corporation,” this limited its exposure under certain legal theories. Additionally, she noted that merely being part of an alleged conspiracy was insufficient for establishing jurisdiction.
Judge Lin also highlighted that one plaintiff’s participation with a Washington-based CHL club did not substantiate jurisdictional claims and mentioned that any agreements between NHL and CHL applied uniformly across all drafted players.
With this ruling, Judge Lin did not address other arguments related to standing or exemptions presented by NHL. The court also granted CHL defendants’ dismissal on grounds including FTAIA and international comity.
The legal team from Paul, Weiss included litigation partners Andrew Gordon and Martha Goodman.
