IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
Maurice Clarett .
: CIVIL ACTION NO.: 03-CV-7441
Plaintiff, :
: COMPLAINT
V. . . JURY TRIAL DEMANDED
:
National Football League, Inc. : . .
Defendant. :
PARTIES AND JURISDICTION
1. Plaintiff Maurice Clarett ("Clarett") is an individual with a primary
Youngstown, Ohio.
2. Defendant National Football League, Inc. ("defendant" or WFL") is an
doing business and registered to do business in New York, with an office located at 280
Avenue, New York, New York 10017.
3. Jurisdiction is founded upon 28 U.S.C. $1331. Specifically, the federal
arises under the Sherman Act, 1.5 U.S.C. 51-3, and the Clayton Act, 15 U.S.C. $15.
4. Venue is laid in this district ,pursuant to sections 4, 12 and 16 of
and15 USC. $1391(b), (c) and (d).
5. The defendant maintains offices, has agents, transacts business, and/or
within this judicial district. The cause of action alleged herein arose in part within
The interstate trade and commerce described herein is and has been carried out within this
district.
TRADE AND COMMERCE
6. The activities of the defendant, as described in this Complaint, occurred
interstate commerce; had, and continue to have, a substantial effect on interstate trade
commerce; and have unreasonably restrained, and continue to restrain, interstate trade and
SNIPPETS:
Defendant National Football League, Inc. is an entity
doing business and registered to do business in New York, with an office located at 280 Park
Avenue, New York, New York 10017.
arises under the Sherman Act, 1.5 U.S.C. 51-3, and the Clayton Act, 15 U.S.C. $15.
Venue is laid in this district,pursuant to sections 4, 12 and 16 of the Clayton Act,
The interstate trade and commerce described herein is and has been carried out within this
professional football in the United States.
The NFL is a distinct market for professional football for which there are no
reasonable substitutes in the United States.
The NFL began operating in 1920 as the American Professional Football
the NFL is composed of thirty-two separately incorporated clubs
the NLRB recognized the National Football League Players Association
as a labor organization within the meaning of 29 U.S.C. Section 152.
Collective Bargaining Agreement, which has been extended three times and will not
The Rule is not the product of bona fide arm's length negotiation between the
The purpose of the Rule is to perpetuate a system whereby college football serves
Clarett was born on October 29, 1983 and graduated high school in December
Clarett was a member of his school's football team.
After he graduated from high school, Clarett enrolled in Ohio State University
Draft") but was prevented from doing so by the Rule.
who are not three years removed from high school graduation.
the direct effect of the Rule is a restraint of amateur athletes who
trade, in violation of the Sherman Act, 15 U.S.C. $1 et seq.
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