HOBART-MAYFIELD, INC. v. NATIONAL OPERATING COMMITTEE ON STANDARDS FOR ATHLETIC EQUIPMENT, ET AL. - Articles

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HOBART-MAYFIELD, INC. v. NATIONAL OPERATING COMMITTEE ON STANDARDS FOR ATHLETIC EQUIPMENT, ET AL.

Posted by: Karen Belcher on Sep 9, 2022

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Allen R. Bachman, K&L GATES, LLP, Washington, D.C., for Appellant.

Attorneys 2: ARGUED: David A. Ettinger, HONIGMAN LLP, Detroit, Michigan, for Appellees.

Attorneys 3: ON BRIEF: Allen R. Bachman, K&L GATES, LLP, Washington, D.C., Christopher M. Wyant, K&L GATES, LLP, Seattle, Washington, for Appellant.

Attorneys 4: ON BRIEF: David A. Ettinger, HONIGMAN LLP, Detroit, Michigan, Rodger K. Carreyn, Christopher G. Hanewicz, Gabrielle E. Bina, PERKINS COIE LLP, Madison, Wisconsin, Jeffrey B. Morganroth, MORGANROTH & MORGANROTH, PLLC, Birmingham, Michigan, David A. White, DAVIS & WHITE, LLC, North Andover, Massachusetts, Michael G. Brady, WARNER NORCROSS & JUDD LLP, Southfield, Michigan William S. Cook, Jennifer A. Morante, WILSON ELSER MOSKOWITZ EDELMAN & DICKER, LLP, Livonia, Michigan, for Appellees.

Judge(s): SILER, COLE, and NALBANDIAN, Circuit Judges

Court Appealed: United States District Court for the Eastern District of Michigan at Detroit

SILER, Circuit Judge. Plaintiff Hobart-Mayfield, Inc. (Mayfield) is the maker of a football helmet accessory. The accessory is purported to reduce the severity of football helmet impact when it is installed on an existing football helmet. Defendants are National Operating Committee on Standards for Athletic Equipment (NOCSAE); Riddell, Inc. (Riddell); Kranos Corp. (d/b/a/ Schutt Sports); and Xenith, LLC (Xenith) (collectively “Helmet Manufacturers”). NOCSAE is a nonprofit organization that develops and promotes safety standards for athletic equipment. It has a safety certification that can be applied to football helmets that meet NOCSAE’s standards. Helmet Manufacturers are makers of football helmets. Mayfield filed a complaint alleging that NOCSAE and Helmet Manufacturers are restraining trade in the football-helmet market, engaging in an overarching conspiracy to limit competition, and subjecting Mayfield to tortious interference of business relationships or expectations. Mayfield’s complaint was met with Defendants’ Rule 12(b)(6) motion to dismiss on the basis that Mayfield failed to state a claim for plausible relief. The district court granted Defendants’ motion to dismiss. We AFFIRM.

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