`
`
`
`BARBARA J. PARKER (Bar No. 69722)
` bparker@oaklandcityattorney.org
`OTIS McGEE JR. (Bar No. 71885)
` omcgeejr@oaklandcityattorney.org
`MARIA BEE (Bar No. 167716)
` mbee@oaklandcityattorney.org
`ERIN BERNSTEIN (Bar No. 231539)
` ebernstein@oaklandcityattorney.org
`OAKLAND CITY ATTORNEY
`One Frank Ogawa Plaza, 6th Floor
`Oakland, California 94612
`Telephone: (510) 238-3601
`Facsimile: (510) 238-6500
`
`CLIFFORD H. PEARSON (Bar No. 108523)
` cpearson@pswlaw.com
`DANIEL L. WARSHAW (Bar No. 185365)
` dwarsshaw@pswlaw.com
`MICHAEL H. PEARSON (Bar No. 277857)
` mpearson@pswlaw.com
`MATTHEW A. PEARSON (Bar No. 291484)
` mapearson@pswlaw.com
`PEARSON, SIMON & WARSHAW, LLP
`15165 Ventura Boulevard, Suite 400
`Sherman Oaks, California 91403
`Telephone: (818) 788-8300
`Facsimile: (818) 788-8104
`
`[Additional Counsel Listed on Signature Page]
`
`Attorneys for Plaintiff City of Oakland
`
`
`
`
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`
`
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`JAMES W. QUINN
` jquinn@bafirm.com
`DAVID BERG
` dberg@bafirm.com
`MICHAEL M. FAY
` mfay@bafirm.com
`JENNY H. KIM
` jkim@bafirm.com
`CHRISTOPHER L. SPRENGLE
` csprengle@bafirm.com
`BRONWYN M. JAMES
` bjames@bafirm.com
`BERG & ANDROPHY
`120 West 45th Street, 38th Floor
`New York, New York 10036
`Telephone: (646) 766-0073
`Facsimile: (646) 219-1977
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA, OAKLAND DIVISION
`
`
`
` CASE NO.
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`COMPLAINT FOR DAMAGES
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`JURY TRIAL DEMANDED
`
`CITY OF OAKLAND,
`
`
`Plaintiff,
`
`
`
`v.
`
`
`THE OAKLAND RAIDERS, A
`CALIFORNIA LIMITED PARTNERSHIP;
`ARIZONA CARDINALS FOOTBALL CLUB
`LLC; ATLANTA FALCONS FOOTBALL
`CLUB, LLC; BALTIMORE RAVENS
`LIMITED PARTNERSHIP; BUFFALO
`BILLS, LLC; PANTHERS FOOTBALL,
`LLC; THE CHICAGO BEARS FOOTBALL
`CLUB, INC.; CINCINNATI BENGALS,
`INC.; CLEVELAND BROWNS FOOTBALL
`COMPANY LLC; DALLAS COWBOYS
`
`899062.9
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`Case 3:18-cv-07444-JCS Document 1 Filed 12/11/18 Page 2 of 49
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`
`
`FOOTBALL CLUB, LTD.; PDB SPORTS,
`LTD.; THE DETROIT LIONS, INC.; GREEN
`BAY PACKERS, INC.; HOUSTON NFL
`HOLDINGS, LP; INDIANAPOLIS COLTS,
`INC.; JACKSONVILLE JAGUARS, LLC;
`KANSAS CITY CHIEFS FOOTBALL
`CLUB, INC.; CHARGERS FOOTBALL
`COMPANY, LLC; THE RAMS FOOTBALL
`COMPANY, LLC; MIAMI DOLPHINS,
`LTD.; MINNESOTA VIKINGS FOOTBALL,
`LLC; NEW ENGLAND PATRIOTS LLC;
`NEW ORLEANS LOUISIANA SAINTS,
`LLC; NEW YORK FOOTBALL GIANTS,
`INC.; NEW YORK JETS LLC;
`PHILADELPHIA EAGLES, LLC;
`PITTSBURGH STEELERS LLC; FORTY
`NINERS FOOTBALL COMPANY LLC;
`FOOTBALL NORTHWEST LLC;
`BUCCANEERS TEAM LLC; TENNESSEE
`FOOTBALL, INC; PRO-FOOTBALL, INC.;
`and THE NATIONAL FOOTBALL
`LEAGUE,
`
`
`Defendants.
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`899062.9
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`I.
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`II.
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`III.
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`IV.
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`V.
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`Case 3:18-cv-07444-JCS Document 1 Filed 12/11/18 Page 3 of 49
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`TABLE OF CONTENTS
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`Page
`
`PRELIMINARY STATEMENT ........................................................................................... 2
`
`PARTIES ............................................................................................................................... 8
`
`JURISDICTION AND VENUE .......................................................................................... 11
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`INTRADISTRICT ASSIGNMENT .................................................................................... 11
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`FACTUAL ALLEGATIONS .............................................................................................. 11
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`A.
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`Background ............................................................................................................. 11
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`1.
`
`2.
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`The NFL’s Complete Market Power Over NFL Franchise Locations ........ 11
`
`The NFL’s Relocation Process .................................................................... 14
`
`(a)
`
`(b)
`
`The Relocation Policies ................................................................... 14
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`The Relocation Fee .......................................................................... 16
`
`3.
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`The Raider’s History In Oakland ................................................................ 17
`
`(a)
`
`The Raiders’ Identity Is Inextricably Linked With Its
`Oakland Fans ................................................................................... 17
`
`(b)
`
`The Hectic Al Davis Years .............................................................. 17
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`B.
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`The Raiders’ Unlawful Relocation From Oakland ................................................. 20
`
`1.
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`2.
`
`3.
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`The Raiders And NFL Decide To Leave Oakland ...................................... 20
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`The Raiders’ Pretextual And Bad Faith Negotiations With Oakland ......... 21
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`Defendants’ Collusive Relocation Fee Determination And
`Relocation Vote ........................................................................................... 24
`
`The Unlawful Conspiracy Behind The Raiders’ Relocation ................................... 28
`
`The Relevant Market Applicable To Defendants’ Misconduct............................... 30
`
`Defendants’ Conduct Has Injured Competition ...................................................... 31
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`Defendants’ Anticompetitive Conduct Has Injured Plaintiff .................................. 32
`
`C.
`
`D.
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`E.
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`F.
`
`VI.
`
`CAUSES OF ACTION ....................................................................................................... 32
`
`COUNT I: Violation of the Sherman Act (15 U.S.C. § 1) Group Boycott:
`Damages/Disgorgement .......................................................................................... 32
`
`COUNT II: Violation of the Sherman Act (15 U.S.C. § 1) Refusal to Deal:
`Damages/Disgorgement .......................................................................................... 34
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`Case 3:18-cv-07444-JCS Document 1 Filed 12/11/18 Page 4 of 49
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`COUNT III: Violation of the Sherman Act (15 U.S.C. § 1) Price Fixing:
`Damages/Disgorgement .......................................................................................... 36
`
`COUNT IV: Violation of the Sherman Act (15 U.S.C. § 1) Declaratory Judgment .......... 37
`
`COUNT V: Breach of Contract (Cal. Civ. Code § 1559) Damages .................................. 39
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`COUNT VI: Quantum Meruit Restitution ......................................................................... 41
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`COUNT VII: Unjust Enrichment Under California Law Damages/Disgorgement ........... 43
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`VII.
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`PRAYER FOR RELIEF ...................................................................................................... 44
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`VIII. DEMAND FOR JURY TRIAL ........................................................................................... 45
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`COMPLAINT FOR DAMAGES
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`Case 3:18-cv-07444-JCS Document 1 Filed 12/11/18 Page 5 of 49
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`Plaintiff City of Oakland (“Oakland” or “Plaintiff”), by and through its attorneys, the
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`Offices of the Oakland City Attorney; Berg & Androphy; and Pearson, Simon & Warshaw, LLP,
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`as and for its complaint against Defendants The Oakland Raiders, a California Limited
`
`Partnership, d/b/a Oakland Raiders (“Raiders”); Arizona Cardinals Football Club LLC, d/b/a
`
`Arizona Cardinals (“Cardinals”); Atlanta Falcons Football Club, LLC, d/b/a Atlanta Falcons
`
`(“Falcons”); Baltimore Ravens Limited Partnership, d/b/a Baltimore Ravens (“Ravens”); Buffalo
`
`Bills, LLC, d/b/a Buffalo Bills (“Bills”); Panthers Football, LLC, d/b/a Carolina Panthers
`
`(“Panthers”); The Chicago Bears Football Club, Inc., d/b/a Chicago Bears (“Bears”); Cincinnati
`
`Bengals, Inc., d/b/a Cincinnati Bengals (“Bengals”); Cleveland Browns Football Company LLC,
`
`d/b/a Cleveland Browns (“Browns”); Dallas Cowboys Football Club, Ltd., d/b/a Dallas Cowboys
`
`(“Cowboys”); PDB Sports, Ltd., d/b/a Denver Broncos (“Broncos”); The Detroit Lions, Inc., d/b/a
`
`Detroit Lions (“Lions”); Green Bay Packers, Inc., d/b/a Green Bay Packers (“Packers”); Houston
`
`NFL Holdings, LP, d/b/a Houston Texans (“Texans”); Indianapolis Colts, Inc., d/b/a Indianapolis
`
`Colts (“Colts”); Jacksonville Jaguars, LLC, d/b/a Jacksonville Jaguars (“Jaguars”); Kansas City
`
`Chiefs Football Club, Inc., d/b/a Kansas City Chiefs (“Chiefs”); Chargers Football Company,
`
`LLC, d/b/a Los Angeles Chargers (“Chargers”); The Rams Football Company, LLC, d/b/a Los
`
`Angeles Rams (“Rams”); Miami Dolphins, Ltd., d/b/a Miami Dolphins (“Dolphins”); Minnesota
`
`Vikings Football, LLC, d/b/a Minnesota Vikings (“Vikings”); New England Patriots LLC, d/b/a
`
`New England Patriots (“Patriots”); New Orleans Louisiana Saints, LLC, d/b/a New Orleans Saints
`
`(“Saints”); New York Football Giants, Inc., d/b/a New York Giants (“Giants”); New York Jets,
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`LLC, d/b/a New York Jets (“Jets”); Philadelphia Eagles, LLC, d/b/a Philadelphia Eagles
`
`(“Eagles”); Pittsburgh Steelers, LLC, d/b/a Pittsburgh Steelers (“Steelers”); Forty Niners Football
`
`Company LLC, d/b/a San Francisco 49ers (“49ers”); Football Northwest LLC, d/b/a Seattle
`
`Seahawks (“Seahawks”); Buccaneers Team LLC, d/b/a Tampa Bay Buccaneers (“Buccaneers”);
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`Tennessee Football, Inc., d/b/a Tennessee Titans (“Titans”); and Pro-Football, Inc., d/b/a
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`Washington Redskins (“Redskins,” and with the Raiders, Cardinals, Falcons, Ravens, Bills,
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`Panthers, Bears, Bengals, Browns, Cowboys, Broncos, Lions, Packers, Texans, Colts, Jaguars,
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`Chiefs, Chargers, Rams, Dolphins, Vikings, Patriots, Saints, Giants, Jets, Eagles, Steelers, 49ers,
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`1
`COMPLAINT FOR DAMAGES
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`Case 3:18-cv-07444-JCS Document 1 Filed 12/11/18 Page 6 of 49
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`Seahawks, Buccaneers and Titans, the “NFL Clubs”); and The National Football League (“NFL,”
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`and with the NFL Clubs, the “Defendants”), allege as follows:
`I.
`
`PRELIMINARY STATEMENT
`1.
`
`This is an action for damages and other relief arising out of the Defendants’
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`unlawful decision to boycott Oakland, as the host city of the Raiders, and relocate the Raiders to
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`Las Vegas, Nevada.
`2.
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`In 2017, the Raiders announced that they were leaving Oakland for Las Vegas.
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`Although Oakland went to extraordinary efforts to keep the Raiders from leaving, the ultimate
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`calculation was purely monetary: Las Vegas offered $750 million, ostensibly for a new stadium,
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`and the Raiders are paying $378 million to the NFL Clubs for voting “yes” on the Las Vegas
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`relocation. This $378 million “relocation fee” served no legitimate purpose and, instead, skewed
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`the bidding process for the Raiders in favor of relocation by enriching the NFL Clubs for their
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`positive votes for the Raiders’ move. While Oakland proposed a $1.3 billion new stadium that
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`included a mix of public and private funding to the tune of $750 million, Oakland’s offer did not,
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`and could not, put tens of millions of additional dollars in additional supra-competitive cartel
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`payments in the form of a relocation fee directly into the pockets of each of the remaining 31 NFL
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`Club owners. Only relocating the Raiders did.
`3.
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`The Raiders’ move – and the bidding process which preceded it – violated not only
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`the antitrust laws, but also the NFL’s own relocation policies. More than 35 years ago, the United
`
`States Court of Appeals for the Ninth Circuit affirmed that Article 4.3 of the NFL Constitution and
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`Bylaws (“NFL Constitution,” attached hereto in its entirety as Exhibit “1”) – which requires three-
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`fourths approval of all NFL Clubs for team relocations – amounted to an unreasonable restraint of
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`trade in violation of Section 1 of the Sherman Act because no objective standards or durational
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`limits were incorporated into the voting requirements. Los Angeles Memorial Coliseum Comm’n
`
`v. National Football League, 726 F.2d 1381 (9th Cir. 1984). The Ninth Circuit found that, while
`
`some collective restraints may be necessary to producing a successful NFL product, such restraints
`
`must be closely tailored to advancing that purpose in order to withstand antitrust scrutiny. The
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`court enumerated objective considerations – then lacking in Article 4.3 – such as population,
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`899062.9
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`Case 3:18-cv-07444-JCS Document 1 Filed 12/11/18 Page 7 of 49
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`economic projections, facilities, regional balance, fan loyalty, and team rivalries, among others,
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`that should guide Defendants’ territorial allocations of NFL teams in order to mitigate their
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`collective actions under the rule of reason. In response to the Ninth Circuit’s antitrust ruling
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`against it, and to ensure future relocation decisions withstand antitrust scrutiny, the NFL
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`subsequently adopted the Policy and Procedures for Proposed Franchise Relocations (the
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`“Relocation Policies” or “Policies,” attached hereto as Exhibit “2”) that ostensibly incorporate the
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`At the outset, the Relocation Policies expressly confirm that:
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`objective criteria that the Ninth Circuit ruled were lacking.
`4.
`each club’s primary obligation to the League and to all other member clubs is to
`advance the interests of the League in its home territory. This primary obligation
`includes, but is not limited to, maximizing fan support, including attendance, in its
`home territory.
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`(emphasis added). The Relocation Policies further confirm that “no club has an ‘entitlement’ to
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`relocate simply because it perceives an opportunity for enhanced club revenues in another
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`location.” In other words, the Relocation Policies first and foremost favor a team’s home territory
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`over relocation in order to promote team stability – which is thus clearly one of the procompetitive
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`goals of the Relocation Policies - and all other considerations are viewed through that narrow lens.
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`Because the Relocation Policies were adopted to address Defendants’ antitrust violations,
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`Defendants are not free to disregard them. When Defendants breach the Relocation Policies that
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`are in place to mitigate their collective actions, they essentially re-violate the antitrust laws those
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`Policies were designed to comply with. This has the effect of putting Defendants in the same
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`place they were at the time the Ninth Circuit rendered its decision in Los Angeles Memorial
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`Coliseum 35 years ago, i.e., in violation of the antitrust laws. That is precisely what happened
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`here.
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`5.
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`The Raiders were financially successful in Oakland, received significant support
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`from Oakland, and had one of the most loyal fan bases in the NFL in Oakland (also known as
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`“Raider Nation”). Further, under both Oakland and Las Vegas’ proposals, the Raiders would
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`reportedly contribute $500 million toward building a new stadium, and both proposals involved
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`roughly $600 to $650 million in other private financing.
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`Case 3:18-cv-07444-JCS Document 1 Filed 12/11/18 Page 8 of 49
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`6.
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`Accordingly, under the Relocation Policies (which presumptively favor NFL teams
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`staying in their home territories), there was simply no justification for a Raiders’ relocation.
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`However, Defendants openly ignored those Policies and approved the Raiders’ relocation not
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`because of some perceived lack of support by Oakland – or some concern about what Oakland was
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`willing to pay or not pay toward a new or renovated stadium – but because of the supra-
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`competitive payment Defendants coerced from Las Vegas which they would individually pocket
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`by supporting the move.
`7.
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`Most egregiously, Defendants knowingly trampled on the Relocation Policies while
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`publicly promising Oakland that they would negotiate in good faith. These statements were
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`blatant misrepresentations and a direct violation of those Policies, which require that Defendants
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`negotiate in good faith. From 2014 to 2017, the Raiders, through their owner representative, Mark
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`Davis, publicly stated their desire to stay in Oakland (presumably to continue to reap massive
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`profits at the expense of Raiders fans and the citizens of Oakland) while they affirmatively sought
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`to move anywhere else: San Antonio, Los Angeles, San Diego, or Las Vegas. In fact, at one
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`point, Davis simply stopped speaking to Oakland’s Mayor, Libby Schaaf. By 2016, the NFL
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`became directly involved through Eric Grubman (“Grubman”), its Executive Vice President in
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`charge of stadia and relocations. Although Grubman supposedly “negotiated” with Oakland, he
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`actually criticized Oakland’s every move, including its $1.3 billion proposal for a new stadium
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`near the Coliseum, the current home of the Raiders. The Raiders, the NFL, and ultimately the vast
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`majority of NFL Clubs, were just stringing Oakland along as part of their collusive scheme to
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`move the Raiders.
`8.
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`For decades, Defendants have tightly limited the supply and territorial allocation of
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`the professional football teams in the United States by not only limiting the number of NFL Clubs
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`in the United States, but also collectively controlling, and dictating under what terms and
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`conditions, cities can have a professional football team presence. There are just 32 teams for the
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`entire United States and thus cities fiercely compete to be a host city (“Host City”). A three-
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`fourths vote of all 32 NFL Club owners is required to determine what city a team calls its home,
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`and under what terms and conditions, including the price. The “price” includes not only hundreds
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`Case 3:18-cv-07444-JCS Document 1 Filed 12/11/18 Page 9 of 49
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`of millions of dollars in taxpayer money to be committed to building billion-plus dollar stadia to
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`benefit the billionaire club owners, but also the “relocation fee” component that – in recent years –
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`amounts to hundreds of millions of additional dollars that are paid to the other 31 NFL Club
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`owners whose collective votes control whether a team relocates or stays put. Like the Raiders’
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`move, the recent relocations of the Rams and Chargers also generated hundreds of millions in such
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`fees for the remaining NFL Club owners, including Raiders owner Mark Davis. Notably, not a
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`cent out of these fees is actually committed to directly accommodating any relocation-related
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`expenses.
`9.
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`This is not a fair process in a competitive marketplace: It is a NFL-rigged process
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`that, contrary to the Policies, promotes relocations in order to further line the pockets of NFL Club
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`owners with millions of dollars paid by their billionaire competitors to the sole detriment of the
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`Host Cities that are unwilling or unable to pay. It is, essentially, a leveraging of the NFL’s
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`monopoly power, used to extract value from municipalities through an auction that ignores the
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`court-mandated objective relocation procedures. Every one of the Relocation Policies’
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`considerations and factors supported a decision to keep the Raiders in Oakland. However, as a
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`Host City, Oakland was unable to pay Defendants’ cartel fee, so the Raiders are moving and
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`paying a bogus $378 million relocation fee.
`10. Worse yet, the Relocation Policies provide no real standard for setting the
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`relocation fee other than it “will compensate other member clubs of the League for the loss of the
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`opportunity appropriated by the relocating club and/or the enhancement (if any) in the value of the
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`franchise resulting from the move.” This guideline indicates that there must be some tangible and
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`objective economic “value” to relocating a team to support a particular relocation fee. However,
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`the factors to be supposedly considered are so vague that they support setting the fee as high as
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`Defendants desire whether the relocating team gains or loses value from the move. But this has
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`not always been the case; when the Rams left Los Angeles for St. Louis in 1995, they were
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`charged $29 million, which clearly had more to do with the fact that there were 29 other NFL
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`teams at the time, rather than any relative comparison of the value of the St. Louis market they
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`took and the Los Angeles market they returned to the league. Here, objective factors indicate that
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`Case 3:18-cv-07444-JCS Document 1 Filed 12/11/18 Page 10 of 49
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`the Defendants lose significant value, with the Raiders moving from a market with proximity to
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`vibrant and wealthy economic hubs like Silicon Valley and San Francisco/Oakland to a city of
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`transient vacationers (Las Vegas), and from the 6th largest media market in the country
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`(encompassing Oakland) to the 40th (encompassing Las Vegas). Thus, this case demonstrates the
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`sheer arbitrariness of the process by which Defendants set relocation fees and generally decide on
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`team relocations.
`11.
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`The costs of Defendants’ collective scheme is enormous, particularly to the public
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`who bear the brunt of Defendants’ anti-competitive conduct – whether in hundreds of millions of
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`tax dollars committed to new stadia and paying Defendants’ relocation fees, supra-competitive
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`ticket and seat licensing fees justified by gigantic and expensive stadia, or in lost investment and
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`business opportunities when an incumbent Host City, like Oakland, loses a team. And none of this
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`even begins to consider the toll on the Host City fans who are not only emotionally invested in a
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`local team, but spend considerable sums of money on team merchandise. Because of the great
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`demand for professional football, on the one hand, and Defendants’ collective market power over
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`the allocation of professional football teams to Host Cities, on the other, Defendants can demand
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`supra-competitive terms – often involving new or renovated stadia at enormous cost to Host Cities
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`and ultimately the members of the public. This is a case of leveraging of monopoly power,
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`resulting in an anticompetitive wealth transfer from municipalities to private business, in violation
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`of the antitrust laws.
`12.
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`As a core part of the process of demanding these stadia, NFL Clubs, assisted by the
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`NFL, employ the relocation threat: pay up or watch your team move somewhere else. Other NFL
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`Clubs are only too happy to support these threats: the relocation threats set the floor for all NFL
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`stadium negotiations and – when an NFL Club ultimately does relocate – the other NFL Clubs
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`receive illicit cartel payments in the form of the relocation fee and their own future threats to
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`relocate become all the more credible. Since 2013, three NFL Clubs have made good on these
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`relocation threats: the Rams moved from St. Louis to Los Angeles, the Chargers moved from San
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`Diego to Los Angeles, and the Raiders will be moving from Oakland to Las Vegas. As a result,
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`the NFL Clubs have shared, or will share, in more than $1.4 billion in relocation fees.
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`6
`COMPLAINT FOR DAMAGES
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`Case 3:18-cv-07444-JCS Document 1 Filed 12/11/18 Page 11 of 49
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`13.
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`The NFL’s boycott of Oakland violates the antitrust laws. Specifically, the NFL
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`controls the number of professional football franchises and where they are located, which gives
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`them complete market power. Also, as a cartel, courts have subjected the NFL to antitrust liability
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`in the context of team relocations, and that liability compelled the NFL to adopt the Relocation
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`Policies described above. Contrary to these Policies, Defendants simply boycotted Oakland in
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`favor of Las Vegas, even though Oakland is a lucrative market and made a significant stadium
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`proposal to Defendants to keep the Raiders at home. Once again, Defendants acted in this manner
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`to collect the massive relocation fee that the Raiders’ move generates.
`14. Moreover, Oakland was significantly handicapped in its effort to keep the Raiders
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`by the fact that only a relocation would result in a payment to the other 31 NFL Clubs; there is no
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`mechanism for a Host City to match these payments. So if the Raiders remained in Oakland, the
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`other NFL Clubs would receive nothing. Through this decidedly skewed process, Defendants
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`concertedly refused to deal with Oakland (like the Rams with St. Louis and the Chargers with San
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`Diego before). It was immaterial to Defendants that the Raiders were financially successful in
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`Oakland, received significant support from Oakland, and had one of the most loyal fan bases in the
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`NFL, the Raider Nation. Maximizing their cartel fee – ultimately at the expense of the consuming
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`public and taxpayers – is what really matters to Defendants.
`15.
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`The Defendants’ unlawful conduct has caused Plaintiff significant injury and loss.
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`Among other things, Plaintiff has lost the value of its significant investment in the Raiders, is
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`burdened with a stadium of significantly diminished value, and has lost the revenues generated by
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`the Raiders’ continuing presence. Defendants disregarded every objective factor in the Relocation
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`Policies when they collectively agreed to relocate the Raiders from Oakland, thus concertedly
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`boycotting and refusing to deal with Oakland on objective terms in an effort to maximize their
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`payments, as well as leveraging their monopoly power, by charging supra-competitive prices to
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`another host city (Las Vegas) and the consuming public (fans) for the presence of a professional
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`football team. Because Defendants’ collective action was not grounded in objective criteria and
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`violated their own Relocation Policies, it lacks any pro-competitive justifications.
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`/ / /
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`899062.9
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`COMPLAINT FOR DAMAGES
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`16.
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`Accordingly, Plaintiff brings this action for violations of the antitrust laws and
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`breach of contract, among other claims, arising from Defendants’ unlawful conduct. As
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`demonstrated in more detail below, because of this unlawful conduct, Plaintiff is entitled to,
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`among other remedies, treble damages from Defendants under 15 U.S.C. §§ 1 and 15; a
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`disgorgement of the enormous supra-competitive payments that Defendants have received, and
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`will receive, from their unlawful conduct; and damages for Defendants’ breach of their own
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`Relocation Policies– i.e., Policies to which Plaintiff, as the host of the Raiders, is an intended
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`beneficiary.
`II.
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`PARTIES
`17.
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`Plaintiff City of Oakland is a municipal corporation located in California. Oakland
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`is an indirect owner of the Coliseum at which the Raiders currently play professional football in
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`the NFL.
`18.
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`Defendant The National Football League is an unincorporated association
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`consisting of the NFL Clubs. The NFL’s principal place of business is 345 Park Avenue, New
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`York, New York 10065.
`19.
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`The NFL Clubs are 32 separately-owned and independently-operated professional
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`football franchises organized and operating for profit in the states set forth below. In total, NFL
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`Clubs play, or practice in, at least 23 different states and collectively generate revenue of
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`approximately $14 billion:
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`Defendant NFL Club
`Address
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`Arizona Cardinals Football Club LLC
`8701 Hardy Drive
`Tempe, Arizona 85284
`Atlanta Falcons Football Club, LLC
`4400 Falcon Parkway
`Flowery Branch, Georgia 30542
`Baltimore Ravens Limited Partnership
`1 Winning Drive
`Owing Mills, Maryland 21117
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`State of
`Organization
`(state of operation,
`if different)
`Delaware
`(Arizona)
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`NFL Club Name
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`Arizona Cardinals
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`Georgia
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`Atlanta Falcons
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`Maryland
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`Baltimore Ravens
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`899062.9
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`8
`COMPLAINT FOR DAMAGES
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`Case 3:18-cv-07444-JCS Document 1 Filed 12/11/18 Page 13 of 49
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`Defendant NFL Club
`Address
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`Buffalo Bills, LLC
`One Bills Drive
`Orchard Park, New York 14127
`Panthers Football, LLC
`800 South Mint Street
`Charlotte, North Carolina 28202
`The Chicago Bears Football Club, Inc.
`Halas Hall
`1920 Football Drive
`Lake Forest, Illinois 60045
`Cincinnati Bengals, Inc.
`One Paul Brown Stadium
`Cincinnati, Ohio 45202
`Cleveland Browns Football Company LLC
`76 Lou Groza Boulevard
`Berea, Ohio 44017
`Dallas Cowboys Football Club, Ltd.
`Cowboys Center
`One Cowboys Parkway
`Irving, Texas 75063
`PDB Sports, Ltd.
`13655 Broncos Parkway
`Englewood, Colorado 80112
`The Detroit Lions, Inc.
`222 Republic Drive
`Allen Park, Michigan 48101
`Green Bay Packers, Inc.
`1265 Lombardi Avenue
`Green Bay, Wisconsin 54304
`Houston NFL Holdings, LP
`Two Reliant Park
`Houston, Texas 77054
`Indianapolis Colts, Inc.
`7001 West 56th Street
`Indianapolis, Indiana 46254
`Jacksonville Jaguars, LLC
`One Alltell Stadium Place
`Jacksonville, Florida 32202
`Kansas City Chiefs Football Club, Inc.
`One Arrowhead Drive
`Kansas City, Missouri 64129
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`State of
`Organization
`(state of operation,
`if different)
`Delaware
`(New York)
`
`NFL Club Name
`
`Buffalo Bills
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`North Carolina
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`Carolina Panthers
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`Delaware
`(Illinois)
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`Chicago Bears
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`Ohio
`
`Cincinnati Bengals
`
`Delaware
`(Ohio)
`
`Cleveland Browns
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`Texas
`
`Dallas Cowboys
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`Colorado
`
`Denver Broncos
`
`Michigan
`
`Detroit Lions
`
`Wisconsin
`
`Green Bay Packers
`
`Delaware
`(Texas)
`
`Delaware
`(Indiana)
`
`Delaware
`(Florida)
`
`Texas
`(Missouri)
`
`Houston Texans
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`Indianapolis Colts
`
`Jacksonville Jaguars
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`Kansas City Chiefs
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`COMPLAINT FOR DAMAGES
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`Case 3:18-cv-07444-JCS Document 1 Filed 12/11/18 Page 14 of 49
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`State of
`Organization
`(state of operation,
`if different)
`
`NFL Club Name
`
`California
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`Los Angeles Chargers
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`Delaware
`(California)
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`Los Angeles Rams
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`Florida
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`Miami Dolphins
`
`Delaware
`(Minnesota)
`
`Delaware
`(Massachusetts)
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`Delaware
`(Louisiana)
`
`New York
`(New Jersey)
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`Delaware
`(New Jersey)
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`Minnesota Vikings
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`New England Patriots
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`New Orleans Saints
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`New York Giants
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`New York Jets
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`California
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`Oakland Raiders
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`Pennsylvania
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`Philadelphia Eagles
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`Pennsylvania
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`Pittsburgh Steelers
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`Delaware
`(California)
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`San Francisco 49ers
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`Washington
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`Seattle Seahawks
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`Defendant NFL Club
`Address
`
`Chargers Football Company, LLC
`3333 Susan Street
`Costa Mesa, California 92626
`The Rams Football Company, LLC
`29899 Agoura Road
`Agoura Hills, California 91301
`Miami Dolphins, Ltd.
`7500 SW 30th Street
`Davie, Florida 33314
`Minnesota Vikings Football, LLC
`9520 Viking Drive
`Eden Prairie, Minnesota 55344
`New England Patriots LLC
`One Patriot Place
`Foxborough, Massachusetts 02035
`New Orleans Louisiana Saints, LLC
`5800 Airline Drive
`Metairie, Louisiana 70003
`New York Football Giants, Inc.
`Timex Performance Center
`1925 Giants Drive
`East Rutherford, New Jersey 07073
`New York Jets LLC
`1 Jets Drive
`Florham Park, New Jersey 07932
`The Oakland Raiders,
`A California Limited Partnership
`1220 Harbor Bay Parkway
`Alameda, California 94502
`Philadelphia Eagles, LLC
`1 Novacare Way
`Philadelphia, Pennsylvania 19145
`Pittsburgh Steelers LLC
`3400 South Water Street
`Pittsburgh, Pennsylvania 15203
`Forty Niners Football Company LLC
`4949 Centennial Boulevard
`Santa Clara, California 95054
`Football Northwest LLC
`12 Seahawks Way
`Renton, Washington 98056
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`10
`COMPLAINT FOR DAMAGES
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`Case 3:18-cv-07444-JCS Document 1 Filed 12/11/18 Page 15 of 49
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`Defendant NFL Club
`Address
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`Buccaneers Team LLC
`One Buccaneer Place
`Tampa, Florida 33607
`Tennessee Football, Inc.
`460 Great Circle Road
`Nashville, Tennessee 37228
`Pro-Football, Inc.
`21300 Redskin Park Drive
`Ashburn, Virginia 20147
`III.
`
`State of
`Organization
`(state of operation,
`if different)
`Delaware
`(Florida)
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`Delaware
`(Tennessee)
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`Maryland
`(Virginia)
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`NFL Club Name
`