Facts

RCN Capital LLC filed suit against the newly relocated professional football organization The Los Angeles Rams LLC, formerly of St. Louis, Missouri, in relation to a licensing agreement allowing for the purchasing of season tickets.

PLAINTIFF'S CONTENTIONS: Plaintiff alleged that regardless of any relocation, the Rams maintained a contractual obligation to provide its best efforts in selling season tickets to licensees for any games played outside of the home stadium. Plaintiff further alleged that defendant had prior knowledge of RCN's acquisition of the licensing agreement from a third party.

Plaintiff argued that prior knowledge coupled with a request for relocation evidenced bad faith, interference with RCN's contractual agreement, constituted theft and conspiracy to commit theft, and violated antitrust laws. Plaintiff alleged defendants conduct rose to a level beyond a mere contractual breach and violated Connecticut's Unfair Trade Practices Act.

DEFENDANT'S CONTENTIONS: Defendant alleged that the licensing agreement specifically limited purchasers' rights to games played at the Rams home stadium in St. Louis. Defendant argued the licensing agreement thereby expired upon the Rams relocation to a different city.

Result

The court granted defendant's motion for summary judgment. Plaintiff's complaint was denied with prejudice. Defendant's motion to strike was denied as moot.

Other Information

RCN obtained rights to the licensing agreement as collateral from a third party, who defaulted on a loan owed to RCN. The court found that RCN's intention was to resell the acquired tickets for a profit, thereby breaching the licensing agreement themselves. Plaintiff could not prove its own performance of the contract.