In American Needle Inc. v. National Football League, the NFL had entered into an agreement with Reebok for the manufacture of all of its teams' official goods, claiming that all 32 teams were a single entity. American Needle sued on the grounds that the Reebok agreement was an illegal conspiracy under the Sherman Act. The U.S. Supreme Court held that

1. the 32 teams were not a collective unit and were subject to the Sherman Act.
2. the 32 teams were not a collective unit but were exempt from the Sherman Act because of the economic environment of sports.
3. there was no Sherman Act violation.
4. the 32 teams were a collective unit and not subject to the Sherman Act.