## Facts

- The Ontario Hockey League (OHL), a major junior hockey league within the Canadian Hockey League (CHL), serves as a major pipeline to the NHL entry draft.
- The OHL limited each team to three 20-year-old “overage” players.
- The OHL adopted the “Van Ryn Rule,” requiring any signed 20-year-old to have been listed the prior season on a Canadian Hockey Association or USA Hockey registration certificate.
- Because NCAA rules penalize players who have held major-junior registrations, the Van Ryn Rule effectively barred 20-year-old NCAA players who lacked the required prior registration from joining the OHL while preserving NCAA eligibility.
- The NHL Players’ Association and two NCAA players (Aquino and Caron) challenged the Van Ryn Rule as an unlawful restraint of trade under § 1 of the Sherman Act, alleging it restricted player mobility and opportunities.

## Issues

1. Whether the complaint adequately alleged a relevant product market for evaluating the rule’s competitive effects under Sherman Act § 1.
2. Whether the complaint adequately alleged a relevant geographic market for assessing competitive harm.
3. Whether the allegations plausibly stated antitrust injury by showing harm to competition (rather than harm only to individual players) and cured earlier pleading deficiencies.

## Decision

- The Sixth Circuit affirmed dismissal under Federal Rule of Civil Procedure 12(b)(6).
- The court held the second amended complaint still failed to plead a cognizable relevant product market because it defined the market too narrowly and did not account for reasonable substitutes (including other routes to NHL careers such as U.S. colleges/high schools and European leagues).
- The court held the complaint failed to plead a coherent geographic market because it did not plausibly justify limiting the market given the international scope of competing hockey opportunities.
- The court held the complaint alleged, at most, harm to particular players, not harm to the competitive process in a properly defined market.
- Because market definition is required to evaluate competitive effects, the pleading deficiencies warranted dismissal without reaching more detailed merits analysis of the rule’s effects.

## Legal Principles

- A Sherman Act § 1 plaintiff must plead a relevant market, including both a product market and a geographic market, in which anticompetitive effects are assessed.
- A relevant product market must include all reasonably interchangeable substitutes, assessed through concepts such as reasonable interchangeability and cross-elasticity of demand; a market is not cognizable if it ignores obvious substitutes.
- Antitrust injury requires harm to competition in the market, not merely harm to individual competitors or participants.
- Failure to plead a cognizable relevant market can be fatal to a Sherman Act claim at the motion-to-dismiss stage.

## Conclusion

The Sixth Circuit upheld dismissal because the plaintiffs’ antitrust theory depended on a market definition that excluded obvious substitute development paths to the NHL and lacked a plausible geographic boundary, and because the alleged harm was directed to individual players rather than competition in a properly defined market.


National Hockey League Players Ass'n v. Plymouth Whalers Hockey Club, 419 F.3d 462 (6th Cir. 2005)