In the United States, United Kingdom and the European Union, sports leagues — from soccer to golf to ice skating — are testing the boundaries of antitrust and competition laws.

Skadden attorneys Bill Batchelor (partner, Brussels and London), Karen Lent (partner, New York) and Vikram Pandit (associate, Brussels) consider the intersection of sports and competition law on both sides of the Atlantic. Courts in all these jurisdictions are grappling with high-stakes questions concerning conspiracy, commercialism and college athletes. The cases that Bill, Karen and Vikram highlight involve a “super” soccer league in Europe, the NCAA’s amateurism model, salary caps for soccer in England and more. Tune in to hear their insights on  how future rulings could change the game.

💡 Meet Your Host 💡

Name: Vikram Pandit  

Title: Associate, Antitrust/Competition at Skadden

Specialty: Vikram is an associate in Skadden’s global Antitrust/Competition Group based in Brussels. 

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💡 Featured Guests 💡

Name: Bill Batchelor

What he does: Bill Batchelor has 20 years of EU and U.K. competition law experience and focuses his practice on conduct investigations, including abuse of dominance, cartels and vertical agreements. He regularly represents clients on EU and global merger control matters and litigation, and provides counsel on distribution and collaboration agreements in complex and highly regulated industries, such as health care, financial services, insurance, media and entertainment, and gambling, among others.

Organization: Skadden

Words of wisdom: “It's interesting to see that some of these cases going all the way to the highest court in Europe are from individual players. So, it's not big litigation between huge organizations. An individual player can go to their local labor tribunal and that tribunal can refer a question of law directly up to the ECJ, and that can be the source of a new ruling on competition law that can affect a block of 450 million people.”

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Name: Karen Lent

What she does:  Karen Lent is co-head of Skadden’s sports practice and head of the New York office’s antitrust/competition practice, representing a wide variety of clients in antitrust, sports and other complex litigation matters at both the trial and appellate court levels. She also provides general antitrust counseling.

Organization: Skadden

Words of wisdom: “Certainly the kinds of rules — how many players do you have on the field, how many referees, those sorts of things — are the rules of the game, and if someone tries to challenge those from an antitrust perspective, they'd quickly be dismissed ... But if there are rules about how leagues deal with suppliers or customers, those would then be subject to the rule of reason. They would not be exempt from the antitrust laws.”

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Fierce Competition is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. This podcast is provided for educational and informational purposes only and is not intended and should not be construed as legal advice. This podcast is considered advertising under applicable state laws.

Welcome to Fierce Competition, a podcast from Skadden's global antitrust and competition group that explores antitrust policy and enforcement around the world. Join our colleagues from across the continent as we discuss the latest developments and what they mean to you in an increasingly complex legal and regulatory landscape.

Welcome to Skadden's July edition of Fierce Competition, where we'll be discussing recent legal developments relating to how sports and athletes are organized in the EU, UK, and US from the perspective of competition laws. I'm Vikram Pandit, associate in our global antitrust and competition team based in Brussels, and today I'm joined by Bill Batchelor, partner in our Brussels office.

Hi everyone.

And Karen Lent partner in our New York office.

Hi.

Recent decisions in Europe have changed how sports are perceived according to law. Just before the new year, the European Court of Justice was asked to consider in the context of broader litigation whether European Union competition laws would apply to the international governing bodies for figure skating, the International Skating Union or ISU, and soccer, globally FIFA and Europe UEFA. Bill, did the ECJ give governing bodies leeway to operate without limitation from European competition laws?

Great question. It has been open season in relation to sports over the past few years in Europe, normally a relatively staid area of law. We thought in broad terms that yes, competition laws apply. There was some consideration of the special nature of sport so the courts and regulators wouldn't interfere in how the game is organized, but the economics of the game, how you spend money on those broadcasting rights, how you organize the teams to get the benefit of the commercial activities of sports. That was all thought to be fair game. So things got extremely interesting towards the end of the COVID pandemic in the world of football, or should I say soccer with something called the European Super League, 12 to 15 of the biggest names soccer teams in Europe. So think Manchester United, AC Milan, all got together and said we'd like to start our own league of the top tier football teams in Europe and we'd like to pool the broadcasting fees.

But a crucial term of how they were going to cooperate together was we're going to have to get this around the football governing bodies, namely FIFA and UEFA because they're governing statutes to which all these teams are subject, and indeed all the players in these teams are subject, they say You can't organize an alternative tournament without our approval. And if you do that, the potential for sanctions for the teams are expulsion and for the players are bans. So somebody is going to need to work that out and either we get approval or we're going to have to get judicial protection from the fallout of sorting, of establishing our own super league. That's exactly what happened. In between January and April, 2021, the European Super League announces that it's just about to form and UEFA and FIFA come straight out and they say, if you do this, we think you are undermining the fundamentals of our sport.

The whole point of our sport is that teams progress through merit. If you have a breakaway league with self-chosen teams to play against each other, then the basis of grassroots football that teams succeed or fail through merit, that is undermined. So we will ban you and we won't just ban your teams from playing in tournaments, we'll ban each of the players as well. The super league goes to their local court, happens to be in Madrid, and the Madrid court says, well, let's think about this. Arguably, you've got an association of competing football teams in the form of UEFA and FIFA. They are organizing a boycott of a rival tournament. That sounds to me like a potential competition law issue, and that's something we might be able to attack both under 102 as abuse of dominance. So FIFA and UEFA have a monopoly on organizing football events between them, or we might attack it as an anti-competitive agreement because this associations of undertakings their agreeing between them on the collective boycott.

So yeah, there could actually be a prima facie case that I should issue an injunction against UEFA and FIFA. As an aside, this is a fairly exciting thing for them to do as a jurisdictional matter. Remember, this is a Madrid court issuing an injunction against two Swiss entities purporting to regulate global and European competitions in football between them. So the court says, yes, but I'm not sure of the law. I need a determination as to whether EU law, which is what antitrust principles are based on, is correct in saying this could be considered abuse of a dominant position or an anti-competitive collective boycott, and I'm going to send this to the European Court of Justice, the highest court in the land when it comes to Europe. Simultaneously, a little dispute had been bubbling up in the International Skating Union. Two skaters had complained. They said they really wanted to join an alternative tournament.

The governing body said, well, we don't like this alternative tournament ostensibly because there's a lot of betting involved in that alternative tournament and we think that's detrimental to the reputation of the sport. That decision of the ISU have been struck down by the European Commission, appeal from the European Commission goes to the European lower tier court, the general court, and then up to the ECJ. So these two disputes landed at the same time effectively at the ECJ. And the crucial question the ECJ first had to consider is are sports special? Can we say the organization of sport isn't just a hard-nosed commercial enterprise to which competition laws apply in full force. Actually, there is the solidarity among teams, the need to have a merits-based competition, the need for a fair distribution of the wealth, the funds that go into training in grassroots football does that in some way get them a more lenient treatment or a pass.

And that was the threshold question that the Court of Justice had to decide. Almost all the major sporting nations intervened in this case to put forward the point of view that sport is special. They pointed to 165 of the Treaty of the European Union enshrines the special nature of sports, and they said, well, sports should be promoted by the union and its policies and it's something that is in the interest of the health of citizens and you need to factor in these special considerations. The course is very clear, 101 of the judgments said, no, of course union policy should foster sport for the health and well-being of the citizens, but that doesn't overrule antitrust, antitrust bites on hard-nosed commercial decisions.

And when we look at the business of sport, it's a business, the money to be lost or won in these tournaments, the broadcasting rights, how that money is exploited, we grant you, there is a pass for how games are organized. If you're going to tell me there needs to be 11 players in a team, we're not going to say that's anti-competitive because there should be 15 players and the decision on whether breakaway leagues are possible, whether players can participate in alternative tournaments, that is a commercial decision and competition law applies. It was a distillation of earlier cases also. There were no huge surprises there, but it was the first time that the question had been put so bluntly to the Court of Justice when the stakes were so high for European football.

It sounds like the ECJ clearly believes in this notion that the importance of industries to ordinary people must correspond to the extent to which there is a need for it to be governed by competition law and that includes sports. Karen, nothing has changed in this respect recently in the US, but why and how does the perception of sports and indeed the governing bodies or leagues as they're known, differ?

I think one difference is that in Major League Baseball there's a long-standing narrow exemption from the antitrust laws for certain labor conduct. And that differs from what Bill was saying in that arose out of a decision from more than 100 years ago where the Supreme Court of the United States said, Major League Baseball's not involved in interstate commerce. Now that makes no sense today and it's been criticized numerous times, but it's been reaffirmed and so that exemption, it still exists, but outside of that, all of the major leagues are subject to antitrust laws. What's interesting about it here is that when you're talking about the business of the league and the rules that member teams in the leagues agree to, those rules are subject to what we call the rule of reason.

They're considered with respect to their adverse effect on competition versus the pro-competitive effect on competition, because the courts here understand that teams in a league need to work together in order to create the product that they're selling, which is competition. So you need some level of agreement. Certainly the kinds of rules that Bill was talking about, how many players do you have on the field, how many referees, those sorts of things are the rules of the game, and if someone tries to challenge those from an antitrust perspective, they'd quickly be dismissed. Those are absolutely necessary. But if there are rules about how leagues deal with suppliers or customers, those would then be subject to the rule of reason. They would not be exempt from the antitrust laws.

So there are still varying similarities then between the EU and the US in that sports as sports may be okay or as it were, but beyond that, the activities are not outside the remit of competition law in that commercial sense. Bill, you talked very nicely about the ISU and European Super League cases. Keeping in mind then that the ECJ believes these sports are just another activity in many senses to which competition law does apply. What did the court think of the rules they had enacted and the sanctions they had threatened against the players and the teams?

Once you decide that sport isn't special and that you are dealing with the part of it to which antitrust applies with its usual force, the decision was pretty speedy. They said, well, could this be an abuse of a dominant position for somebody who has a monopoly in organizing tournaments to ban another tournament? Short answer, well, yes, clearly that is the kind of thing that could be an abuse. We could have an exception if FIFA or UEFA tells us they're acting in their governing role. So if there were clear criteria to establish a new tournament, the kind they would apply to their own new tournaments. If they apply to others the same rules they apply to themselves, they set it out clearly in advance. There's no room for conflicts of interest. It's all transparent. It can easily be decided, that wouldn't be subject to antitrust, that we see as legitimate.

But if you are effectively saying, we have discretion whether or not to ban a competing tournament that looks like an abuse of dominance and we'll recast that. We'll say now that FIFA and UEFA are an association of competitors and that these rules are a decision of that association of competitors. And then yeah, that's exactly the kind of rule that we would expect to be treated as a collective boycott of a new competitor and the court went further than that. We have two kinds of anti-competitive agreement rather like the US rather than per se, we have something called bi-object. So it's sufficient that the intention is there even if the effects may not be, and we have bi-effect based violations. And the court said here it's sufficiently clear what the intent was that this is a bi-object violation, so there's no need for European Super League to prove any effects.

The European Super League still has not launched. I think the PR around their launch has held them back perhaps, but in principle, legally the Court of Justice tried to create an arguably clear path for them in antitrust terms and it was a similar result in ISU. So the court didn't buy the fact that trying to discourage associations with gambling was a sufficiently legitimate reason to stop players joining an alternative tournament. These were relatively established rules, but there have been a slew of additional cases bubbling up both in the UK and in Europe, some of which will involve further referrals to the Court of justice, no doubt in due course, things like the organization of requiring teams to play additional games, even though they say, well actually we've got a full fixture calendar, is that unfair? Does it breach fundamental rights?

And perhaps just one again, procedural aside, it's interesting to see that some of these cases going all the way to the highest court in Europe are from individual players. So it's not big litigation between huge organizations. An individual player can go to their local Labor Tribunal and that tribunal can refer a question of law directly up to the ECJ, and that can be the source of a new ruling on competition law that can affect a block of 450 million people.

I think it's fair to say that the court's message to any governing bodies is clear. Competition law in the EU may be applied strictly to their commercial arrangements. They should ensure that any rules that relate to others' participation in different competitions, be it the players or other teams are supported by the procedure and criteria designed to meet those standards that you're discussing. Karen, based on what you've said already about the rule of reason, one could suppose questions of law like the ISU case and the Super League case might've been determined slightly differently in the US. Are there any contrasting examples?

So right now, actually there's a case going on in the soccer world also that was filed by the North American Soccer League against US Soccer and Major League Soccer. And it's a good example of how a court is not treating sports special in the US but just applying typical antitrust laws to a venture that requires sanctioning in some sort of way. In that case, the North American Soccer League alleges that US Soccer and Major League Soccer conspired to exclude it and others from competing against Major League Soccer in the antitrust market for top tier men's professional soccer leagues in North America. US Soccer maintains professional league standards which establish the basic requirements for leagues to be categorized and they're categorized as Division I, II or III with Division I being the highest. Major League Soccer is the only Division I soccer league in North America. And for a long time, the North American Soccer League had been a Division II league.

It had tried to move up and was denied. And so the case is based on an argument that somehow the US Soccer and Major League Soccer had conspired to keep the North American Soccer League out and you just apply traditional antitrust principles to that allegation. And that's what the court recently did here in the US in denying summary judgment there. And it said, we don't have any direct evidence of a conspiracy among these two entities, but what we can do and what we do in any case like this, is we look at an inference of conspiracy. We look at the evidence that might be suggestive of a conspiracy, and it held that there was enough evidence that there could have been an agreement among those two entities to exclude the North American Soccer League, and that included the fact that US Soccer began enforcing its standards to be considered Division I, II or III in exactly the same year that the North American Soccer League emerged as a potential competitor.

In the past, it hadn't really enforced those standards allegedly, and it had given waivers to Major League Soccer and said, "Oh, it's okay. You don't need to comply with all of these rules. We'll still grant you that division one status." Well, according to the North American Soccer League, it didn't get those same waivers. It was held to a much more strict compliance with the rules. And then it also alleged that there were some financial and organizational entanglements between US Soccer and Major League Soccer that suggested that perhaps they were acting together. But those familiar with US antitrust laws would say those are the kinds of allegations and facts that plaintiffs try to prove in any case where you're trying to allege an agreement. You're looking at whether it might be against the party's self-interest to engage in activities the way it did, and here the court said applying those rules, I think this case can move forward.

So I think it's a good example of how sports aren't special, they're subject to the same standards just as Bill was saying. Trial is going to begin in September and we'll see what happens. There are other examples just sticking to the unsanctioned leagues or competitions theme that Bill was talking about in the soccer world where we've seen those sorts of issues arise in the US more recently. I think I also have to mention the PGA Tour, LIV Golf matter, which is a little older than some of these things that we've been talking about, but it is very, very similar again to having upstart leagues recruiting players away from long-term established leagues. And in the US, we've seen a bunch of these cases come up where you might have the incumbent league with a lot of power and upstart league trying to start, but not really being able to get its footing.

The PGA Tour and LIV Golf was sort of the exact opposite. You had a highly funded league that was able to recruit star players away from the PGA Tour, and there are some of the players that had been recruited away filed suit against the PGA Tour saying, hey, it's not okay for you to ban me and prevent me from participating in your events just because I joined this competitive league. And they moved for a temporary restraining order, pretty extraordinary relief because they wanted to be able to compete in the end-of-season, sort of high-money events. The court denied that request and it found that those players couldn't establish irreparable harm, which is a requirement for that sort of preliminary injunctive relief in the US that said, look, you're playing, you've got a full slate of events, you're getting paid a lot of money. Why do you need to also be a member of this other competing league, which has valid reasons for not wanting you to be able to free ride off of the opportunity you have in that league and help a competitor?

The fact that the tour had said, no, we're not going to allow these players to play for us and play for our competitor, maybe wouldn't come out the same way in the EU, but in the US for sure it was, let's look at whether this is a true antitrust violation and there can't be an anti-competitive effect here when these players actually have a great opportunity. They're making more money, they're out there playing golf. So I think those cases demonstrate that bit of difference in the way that the antitrust laws are being applied here in the US versus EU with respect to sports organizations.

It seems there's a real distinction between the approach on both sides of the Atlantic, and it'll be interesting to see if they start to converge in some way. There have also been some questions asked about existing rules in which athletes may play for a specific team. For instance, UEFA along with most EU member states soccer associations have always had rules requiring teams to contract a minimum number of players originating from or having been trained for at least three years before the age of 21 in the country where they're based. This is the so-called Homegrown Players Rule. Bill, do you want to tell us how that rule came to end being considered by the ECJ thanks to one Belgian soccer team?

So the Belgian Royal Antwerp football team, they said, hang on, if you are to tell me if there's some sort of employment law rule that says we could only hire certain people from one country, that would clearly restrict free movement of people between European countries. That's a founding treaty principle that you should be free to work wherever you like. Also, it's a global talent market for great players in soccer. If you're telling me I have to source locally, sure, I might have great local players, but equally I may be missing out on huge opportunities. It's stopping me compete at the top level if I can't go after that international talent and I have to nurture my homegrown players. So isn't that also a restriction on competition? These are international soccer rules, therefore it is an association of competitors that's forcing that on me and surely that's a competition problem.

And so that one is now pending before the Belgian courts. It went up to the ECJ and the ECJ said, well, yeah, we can completely see it could be a restriction on free movement of people. It could also be a restriction of competition. But unlike ISU and Super League, they don't go as far as to say, yes, this is definitely a problem. They say, yeah, we can see legitimate interests at stake here. We can see that it is great for nurturing domestic talent. It may be a better product for the audience if they can see local homegrown talent playing in the local teams.

So the court will have to consider, are there legitimate interests here? Are there benefits to the output in terms of a better competition? But if you can't, then yeah, in principle, that could also be a restriction on competition. But it is another example of competition law interfering not just in the economics of sport but getting really into the nitty-gritty of how sports are organized, how players are transferred and the T's and C's of the players and getting pretty close one might say to the rules of the game, which is an area the courts have said they shouldn't tread.

Absolutely. And Karen, it's interesting because national teams, local recruitment aren't such issues in the US where sports, particularly in the major leagues, they focus on city teams. They recruit based on performance and ability demonstrated through time at college. But that hasn't stopped some issues arising in that area in the US lately. Do you want to tell us more about college athletes recent complaints to the NCAA?

You're right. The reason we don't usually see these kinds of antitrust player disputes in the US is because the major professional leagues, the players are unionized and they enter into collective bargaining agreements with the leagues as sort of multi-employer bargaining units. And there's this push and pull in the United States between labor law and antitrust law where there's a collectively bargained agreement between a multi-employer bargaining unit, like a sports league and a unionized organization of the players. There's an exemption to the antitrust laws because the labor laws favor are favored in that situation. That's not the case in the NCAA where you're talking about student athletes. They are right now not unionized, although that's a hot topic in the US and right now there aren't collective bargaining agreements with college athletes. So the NCAA has faced an array of challenges over the last decade or so relating to restrictions that it puts on student athletes how much they can make and whether they can get what's called name, image, and likeness money, which we could talk about a little bit later.

But one big development that we should talk about is the NCAA's decision just last month to stop enforcing all of its rules that govern transferring between institutions. It used to be that if you were a high level Division I athlete and you wanted to leave one university to go to another and play there, you would've to sit out a year. And that was to discourage people from doing that. But the Department of Justice and 10 states and the District of Columbia sued the NCAA alleging that that restriction on transfer eligibility unreasonably restrained the student athlete's ability to engage in the market for their labor. We all know that labor is a big issue in the US overall, so not surprising that it's an issue for the Department of Justice with respect to student athletes as well. And the NCAA had argued that the rule helped protect the amateur model of college sports by restricting the poaching of student athletes.

If you stay at your school, focus on your studies, you're an amateur. If you're leaving and just going to the next best place to play, you look more like a professional athlete. But the court in December granted the DOJ and the state AG's motion for a temporary restraining order and a preliminary injunction preventing the NCAA from enforcing that rule, and any players that were subject to it had to be given back that year of eligibility that they lost when they transferred. Ultimately, the NCAA entered into a consent decree with the government entities and they agreed that for division one programs and the athletes that play in them, it won't enforce those transfer eligibility rules anymore. It's just one of many restrictions that the NCAA had on student athletes that was intended to protect their amateur status that has been struck down or abandoned in the recent history.

And obviously an even more contentious discussion in recent times, as you mentioned, is this NIL issue.

The biggest recent development in this area came just in May. The NCAA announced a nearly $3 billion settlement for three class actions, antitrust suits that have been filed by former college athletes because they said they were denied compensation pursuant to the NCAA's name, image, and likeness compensation ban. And what's really important about this is that it's signals basically the end of the NCAA's amateurism model. Now the division one kids can transfer between schools without any change to their eligibility and they can get significant money in exchange for their name, image, and likeness, which is sort of getting paid to play, which is what it means to be a professional. So the amateurism model is really taking a lot of hits, but I think the other big takeaway is that the NCAA is going to have a lot of issues implementing these new rules.

It's going to need to figure out first and foremost, and something that's near and dear to my heart, how to distribute this revenue sharing money that they've promised to do in the settlement in a way that compensates players while complying with Title IX, which is a unique rule in the US that requires at a broad level, equal opportunities for male and female student athletes. So if you're looking at the way the NCAA works, the vast majority of revenue comes into these schools for football. That's a male sport, but you've got to give opportunities for women to obtain that sort of NIL money as well. It's going to be very difficult to implement that. And then certainly the NCAA will need to figure out how to police all of this. They'll need a new group to handle NIL enforcement.

So now you've got kids who are being recruited to play college who can get paid NIL money, and you've got the student athletes who are in college that can make a lot of money off of NIL deals, including from the schools themselves. So the whole composition of college athletics here is changing in the US and it's changing in a way that is sort of difficult to control because like I said, there aren't unions in college sports the way they are in professional sports and the unionized activity and the collective bargaining agreements in professional sports allow the parties to come to agreements that will benefit both sides and ultimately benefit the proliferation of the sport and the competitiveness of the sport in college athletics.

So a big change coming and lots to process there. I think we're also seeing something similar in the English Premier League, Bill. Salary caps, for instance, the very common in the US major leagues, but potentially new to English soccer.

Yeah, so this is a recent development in the UK. It won't be surprised to anybody to learn that the biggish cost to any football team in the Premier League is going to be your weekly wage bill. Three to 4 million pounds for leading teams compare maybe half a million for some of the smaller teams. So to try and cut this disparity, the Premier League have suggested that they trial a salary cap for the coming season, limiting player salaries to 85% of revenue generated from merchandising or ticket sales and sales of players over the past season. That's the first time we've seen a salary cap trialed in European football. And it's come at an interesting time because rather like the US, the idea of restricting terms for labor is very much a fashionable antitrust concept and has been the subject of increasing scrutiny by European and UK regulators.

So the question will undoubtedly come up, well, hang on, surely this is exactly how teams compete to attract talent. If you have a salary cap that makes it harder to compete for that talent. For the players themselves, their economic undertakings. Two, they want to earn the best wages that their talent can earn them, their skills may be time limited. Surely that is a competition law complaint in the making. And already the Players' Association for the Premier League players has said that they would challenge any cap in the UK courts. Arguably, even given that many of these are internationals, there could be a nexus to Europe as well, and they might have a chance to take this one to a European court. It'll be interesting to see where this one plays out.

From the point of view of the leagues no doubt, they're saying, well, in order to keep this a competition and progression on the merits, then is it fair that the deepest pockets win? Don't we create a better product, competitive, exciting games if we have a salary cap where we focus on nurturing the talent we have and making these games as equal and as exciting as possible? So you could see an argument there that there are benefits to this rule which might outweigh any restrictions. The burden would shift back to the league themselves to prove that any such benefits accrued, and you could well see that being very hard forced out in the courts. If it comes to litigation.

Bill, it sounds very much like the competitive balance justification that is typically used by professional leagues in the United States when they end the NCAA, frankly, when they're trying to justify why they have limitations on things like player compensation, and it's super hard to prove. I mean, I'm not sure there's actually a decision in the US where that was found to be a pro-competitive justification that won the day. I think a lot of courts talk about it as something that could make sense, but trying to prove that and then trying to prove that there's not a less restrictive way to achieve competitive balance is also really hard because my guess is that the teams aren't limiting spending in other areas.

That was a big issue in one of the NCAA cases where the court said, I understand that this particular rule, limiting compensation might be related to competitive balance, but you have no rules limiting coaching salaries, limiting expenditures on stadiums and the kinds of services that the students can get. So there's got to be a less restrictive way to do this. So it'll be interesting to see how that plays out in the EU. There's a lot of law in the US on it. It's been quite a difficult justification to satisfy.

No doubt both sides will be coming to you Karen for inspiration.

Well, with that, thank you very much Karen, Bill for joining us today and sharing your insights into these updates. Hopefully it'll help the listeners get up to speed on the goings on in sports and competition law. There's clearly a lot going on and there's clearly a lot to come as well, so we'll all be on the lookout to see how it develops.

Thanks, Vikram.

Thank you so much, Vikram, for expertly refereeing this, and I think I can hear the final whistle.

Thank you for joining us for today's episode of Fierce Competition. If you like what you're hearing, be sure to subscribe in your favorite podcast app so you don't miss any future conversations. Additional information about Skadden can be found at skadden.com.