## Facts

- Chicago Professional Sports Limited Partnership (owner of the Chicago Bulls) and WGN, a Chicago “superstation” carried nationwide by cable systems, contracted for WGN to televise Bulls games across the United States. ()  
- During the 1990–91 NBA season, WGN broadcast 25 Bulls games; for the 1991–92 season, it planned to televise 30 Bulls regular‑season games. ()  
- The NBA, organized as a joint venture of its member clubs, controlled national television rights and sold exclusive national packages to NBC (26 regular‑season games) and to TNT (50 cable games), while permitting each team to televise up to 41 games over‑the‑air locally and 41 on local cable. ()  
- Concerned that nationally available Bulls telecasts on WGN would reduce audiences and revenues for other teams and for the league’s national TV partners, the NBA adopted rules limiting “superstations” such as WGN to broadcasting no more than 20 games per season and barring them from competing with TNT broadcasts. ()  
- The Bulls and WGN objected to the superstation cap and filed suit in federal district court, alleging that the NBA’s 20‑game limit was an unlawful restraint of trade under § 1 of the Sherman Act because it reduced the output of televised games and harmed consumer choice. ()  
- The NBA defended the restrictions as reasonable ancillary restraints necessary to the operation of a legitimate joint venture and also invoked the Sports Broadcasting Act as providing antitrust immunity for some of its broadcast arrangements. ()  
- After a prompt, five‑day bench trial, the district court preliminarily enjoined the NBA from enforcing the 20‑game superstation cap, finding it an output‑reducing restraint not justified by procompetitive benefits; other NBA broadcast rules were left for later adjudication. ()  
- The NBA appealed the preliminary injunction to the United States Court of Appeals for the Seventh Circuit, producing the decision commonly referred to as “Bulls I.” ()  

## Issues

1. Whether the NBA’s rule limiting superstation broadcasts of team games (here, WGN’s telecasts of Chicago Bulls games) to 20 games per season constitutes an unlawful restraint of trade under § 1 of the Sherman Act as an output restriction on televised games. ()  
2. Whether the challenged 20‑game superstation cap is a permissible ancillary restraint reasonably necessary to the functioning of the NBA as a joint venture, or instead a naked, anticompetitive limitation on output. ()  
3. Whether and to what extent the Sports Broadcasting Act immunizes the NBA’s broadcast‑rights arrangements, including the superstation cap, from scrutiny under the federal antitrust laws. ()  

## Decision

- The Seventh Circuit held that the NBA’s 20‑game limit on superstation broadcasts of Bulls games was an unlawful restraint of trade under the Sherman Act because it functioned as an output‑reducing restriction on the number of games available to viewers. ()  
- The court concluded that, although the NBA is a joint venture whose cooperative arrangements may require some restraints, the specific 20‑game superstation cap was not shown to be reasonably necessary or procompetitive in its effect. ()  
- The court rejected the NBA’s reliance on the Sports Broadcasting Act as a complete defense, holding that the statute did not immunize the particular superstation limitation at issue from antitrust scrutiny. ()  
- Accordingly, the court of appeals affirmed the district court’s preliminary injunction barring the NBA from enforcing the 20‑game superstation rule against WGN and the Bulls, while leaving challenges to other NBA broadcast rules for further proceedings in the district court. ()  

## Legal Principles

- Professional sports leagues, like the NBA, are treated as joint ventures under antitrust law; cooperative arrangements that are reasonably related to the venture’s legitimate purposes may be upheld as ancillary restraints, but naked restraints on price or output remain unlawful. ()  
- Output restrictions that reduce the number of products (here, televised games) available to consumers are presumptively anticompetitive and must be justified by legitimate, procompetitive objectives closely tied to the operation of the joint venture. ()  
- The Sports Broadcasting Act provides limited antitrust immunity for certain collective selling of league television rights but does not broadly shield all league‑imposed broadcast restraints from Sherman Act review. ()  
- Courts evaluating restraints in the professional sports context may employ a rule‑of‑reason analysis informed by precedents such as NCAA v. Board of Regents, scrutinizing both competitive harms (e.g., reduced output, higher prices, reduced viewer choice) and any proffered efficiencies or justifications. ()  

## Conclusion

The Seventh Circuit in Chicago Professional Sports Ltd. Partnership & WGN v. NBA (Bulls I), 961 F.2d 667 (7th Cir. 1992), affirmed a preliminary injunction preventing the NBA from enforcing its 20‑game cap on WGN’s superstation broadcasts of Bulls games. Treating the NBA as a joint venture but refusing to accept unjustified output restrictions, the court held that the superstation limit violated the Sherman Act and was not immunized by the Sports Broadcasting Act, while leaving broader questions about the league’s broadcast‑rights structure for later proceedings.


Chicago Professional Sports Ltd. Partnership & WGN v. National Basketball Ass’n (Bulls I), 961 F.2d 667 (7th Cir. 1992)