Brooklyn Sports activities & Leisure Legislation Weblog

The staid world {of professional} golf was upended in 2022 with the entry of LIV Golf, a circuit of invitational tournaments that includes each particular person and crew play. Financed by the huge sources of Saudi Arabia’s Public Investment Fund (“PIF”), LIV Golf recruited a number of the world’s high golfers, together with Phil Mickelson and Dustin Johnson, by paying every signing bonuses, look charges, and match purses amounting to tens of thousands and thousands of {dollars}.¹ The breakaway circuit positioned itself as a substitute for the PGA Tour, the highest degree {of professional} golf. On condition that LIV Golf phases its competitions on the identical weekends and sometimes on the identical continent as PGA Tour occasions, the Tour invoked its contractual rights and rules to suspend golfers who took the cash and performed for LIV.² Eleven of these golfers responded with an antitrust lawsuit in opposition to the PGA Tour, filed within the Northern District of California.³ That lawsuit has expanded to incorporate different events and claims, and is now progressing via pretrial discovery.

For extra data on this concern from a UK regulation perspective, please see this LawInSport article.⁴

This text describes the PGA Tour’s monetary and regulatory mannequin and the broader skilled golf ecosystem, as understanding this context is crucial to evaluating the pending antitrust lawsuit. It then examines the antitrust claims that search to dismantle the Tour’s mannequin, particulars the progress of that lawsuit and extra claims and events which have since been added, and explains how LIV Golf’s entry has already reworked the golf ecosystem.

Article define:

Table of Contents

The PGA Tour’s Monetary and Regulatory Mannequin

The PGA Tour, Inc. is organized as a non-profit commerce affiliation. Its membership contains skilled golfers who’ve aggregated their media and publicity rights to collectively negotiate for tv publicity and company sponsorship of their tournaments. ⁵
The worth of these agreements and the income that flows from them is determined by the person golfers’ collective assure of:

consultant fields at tournaments all through the Tour’s season, and
exclusivity as regards to competing golf occasions.

The worth of TV and sponsorship offers resides in aggregating member golfers’ rights and assigning them to the Tour to promote, with the members agreeing to take part in a minimal of 15 Tour occasions over the season, and never take part in conflicting golf occasions and programming. CBS Sports activities would pay loads much less for televising a match if PGA Tour members have been free to play in one other match being held on the identical time, or may individually promote their stay or archival broadcast rights. The member golfers reap the advantage of bundling their rights via richer purses.

Particular person golfers are unbiased contractors, not workers of the commerce affiliation dubbed the PGA Tour. Many particular person skilled sports activities circuits are organized this manner, largely on the behest of the athletes as a result of it supplies them with autonomy and management over their schedules, enterprise alternatives, and funds. It’s the PGA Tour’s Commissioner, executives, and workers who’re workers of the commerce affiliation, which serves as a flow-through entity for compensating the skilled golfers who play in tournaments every year, funding numerous profit plans, and supporting golf-related charities. Annually the composition of the Tour’s membership adjustments as golfers qualify for his or her Tour playing cards primarily based largely on previous efficiency. Notice that the PGA Tour is totally distinct from the PGA of America which is a corporation for membership professionals, i.e., educating execs.

Over the course of a PGA Tour season, member golfers are eligible for 3 or extra “conflicting occasion” releases to play in non-Tour tournaments exterior North America. ⁶ The Commissioner retains discretion to situation these releases on commitments to play in particular Tour occasions sooner or later, or to disclaim releases if it might trigger the Tour to violate a contractual dedication or would hurt the Tour and its sponsors. Releases have been denied to each participant in search of to play in a LIV Golf occasion. Member golfers could resign the Tour at any time to play on a competing tour, together with LIV, or to begin their very own circuit of golf occasions. And some Tour members who defected to LIV did precisely that.⁷

How Does LIV Golf Differ from the PGA Tour

The PGA Tour phases a golf match virtually each weekend of the yr. A typical Tour occasion gives a discipline of between 128 and 156 golfers who compete in opposition to one another over 4 rounds of stroke play (72 holes of golf) to submit the bottom rating. There’s a “reduce” after the primary two rounds, after which about half the sphere continues to compete and stays eligible for prize cash. Previously, gamers who’re reduce have gone dwelling empty-handed, though that has modified to a point since LIV Golf’s emergence. PGA Tour membership requires taking part in not less than 15 tournaments every year to honor commitments made within the sponsorship and media rights offers that fund the purses.

Against this, LIV Golf gives shorter tournaments with smaller fields — three rounds of golf as an alternative of 4 (54 holes), and solely 48 gamers competing in concurrent particular person and crew play occasions. Thus, the identify LIV (rhymes with “give”), which is the Roman numeral for 54. There isn’t a “reduce” in LIV golf occasions. Each golfer performs all three rounds and is assured prize cash that far exceeds potential earnings on the PGA Tour. After the 2022 inaugural season that includes 8 occasions, LIV Golf plans to supply 14 occasions in 2023. Its 48 golfers should decide to taking part in in each occasion and comply with exclusivity provisions analogous to these within the PGA Tour rules. Not like the PGA Tour, LIV is just not depending on TV and sponsorship deals to fund its occasions, though it just lately entered into offers to begin producing such income.⁸[1] Thus far, LIV’s exorbitant signing bonuses and prize cash have been funded virtually totally by the Saudi PIF.

Different Individuals Within the Skilled Golf Ecosystem

One other key participant within the skilled golf ecosystem is the Official World Golf Rankings (“OWGR”), which ranks golfers primarily based on relative efficiency at eligible tournaments, usually solely those who provide the traditional 4 rounds of stroke play. PGA Tour occasions provide essentially the most rating factors as they entice essentially the most expert golfers. Golfers is not going to earn rating factors from LIV occasions until an exception is made—its utility is pending. That can ultimately catch as much as LIV golfers in future years once they contend to play within the unbiased “main” tournaments that aren’t a part of any tour: the Masters, U.S. Open, Open Championship (British), and PGA of America Championship. The majors choose their fields largely primarily based on OWGR rating factors, in addition to prior match victories and qualifying occasions.

Different skilled golf excursions function all through the globe, most elite amongst them the DP World Tour (a.okay.a. the European Tour), which has entered a strategic partnership with the PGA Tour permitting their members to play in both (if certified). The DP World Tour additionally banned its members who performed for LIV from its occasions and fined them every £100,000 for violating its tour rules. Pursuant to these rules, the LIV golfers challenged these disciplinary sanctions in a impartial non-public arbitration, which issued a closing, unappealable resolution upholding the ban and fines.⁹ The PGA Tour additionally operates regional and developmental excursions together with the Tour Latinoamerica and the Korn Ferry Tour. Excursions not affiliated with the PGA Tour embrace the Asian Tour and Center East North Africa (MENA) Tour, each of which obtain Saudi funding.

The Antitrust Lawsuit Early Phases

By mid-2022, LIV had recruited to its circuit 5 of the ten golfers who had earned “participant affect” bonuses on the PGA Tour. In accordance, to media reports the charges LIV promised to these golfers have been astronomical: Phil Mickelson at $200 million, Dustin Johnson at $150 million, and Bryson DeChambeau at $100 million. ¹⁰ LIV was nicely on its approach to filling its ranks for its 48-player circuit when the PGA Tour began suspending members who performed in LIV’s early exhibition tournaments. In August 2022, on the eve of the rankings-critical FedEx Cup collection of PGA Tour occasions, 11 LIV gamers led by Mickelson filed a federal antitrust lawsuit and a movement for a short lived restraining order (“TRO”) to enjoin the PGA Tour’s ban and compel it to permit LIV golfers into the FedEx Cup.¹¹

The antitrust complaint¹² alleged a marketplace for the providers of elite skilled golfers, which the PGA Tour allegedly monopolized (or monopsonized), in violation of the U.S. Sherman Act §2, by requiring unique commitments that barred Tour members from taking part in in conflicting occasions and collaborating in competing golf media programming.¹³The criticism additionally alleged the PGA Tour violated Sherman Act §1 by conspiring with different business members to throw up roadblocks to LIV Golf’s profitable entry.¹⁴

The LIV golfers’ TRO movement argued that they might be irreparably harmed in the event that they weren’t permitted to take part in PGA Tour occasions pending the end result of their antitrust claims. That argument failed and the movement was denied. The U.S. district courtroom discovered that the LIV golfers didn’t overcome the excessive bar for such reduction, primarily as a result of that they had not established irreparable hurt. In an August 10, 2022 order¹⁵,U.S. District Choose Beth Labson Freeman discovered that the LIV golfers haven’t been locked out of their sport or its profitable payouts of prize cash and sponsorship charges. On the contrary, Choose Freeman emphasised that the LIV golfers are incomes considerably extra money than they ever did on the PGA Tour, and that they calculated the cash they might lose from lacking the FedEx Cup once they negotiated their contracts with LIV Golf. As well as, the LIV golfers and their professional witnesses described LIV occasions as “elite golf” that equals if not exceeds PGA Tour occasions in providing significant competitors to the gamers and followers. That place undermined the golfers’ portrayal of the Tour as possessing and abusing monopolistic management over the marketplace for elite golfers’ providers.

With out interim reduction, the LIV golfers’ solely path again to the PGA Tour was litigating their antitrust claims over the various months or years it might take to get to a jury and hopefully a verdict of their favor. That prospect led all however three of the golfer plaintiffs to drop out of the lawsuit, and the LIV Golf entity itself to hitch as a plaintiff.¹⁶ The lawsuit’s emphasis then shifted away from monopolization of the upstream marketplace for skilled golf providers, though the antitrust therapy of a tour’s unique contracts with athletes who’re unbiased contractors stays a stay concern within the case. Nonetheless, the amended criticism focuses on the downstream promotion of elite skilled golf, and PGA Tour actions that allegedly forestall LIV from accessing the enterprise relationships important to getting into and succeeding in that golf market.¹⁷

For instance, the amended criticism alleges that the Tour has conspired with different excursions and the majors to exclude LIV golfers. As of this writing, all 4 of the key tournaments have introduced that LIV golfers will proceed to be eligible to play on the identical qualifying grounds as any participant. The amended criticism additionally alleges that the PGA Tour has conspired with the OWGR to dam LIV occasions from contributing to participant rankings. Maybe in response to that allegation, PGA Tour and DP World Tour representatives on the OWGR Board of Administrators have recused themselves from reviewing LIV Golf’s utility for occasion rating factors.

PGA Tour Goes on the Offensive

After its first vital victory within the lawsuit—the denial of the TRO—the PGA Tour went on the offensive. It filed a proper Reply¹⁸ with the courtroom that units forth its official enterprise causes for establishing and implementing its rules, briefly, to guard sponsors, media companions, and income streams, and to reward and incentivize gamers.¹⁹ The Reply additional makes an attempt to discredit LIV Golf as an under-strategized providing that’s seeks to free-ride on the PGA Tour’s success by forcing the Tour to incorporate LIV golfers to allow them to retain their rankings, celeb, and fan enchantment, which LIV Golf can then exploit. The PGA Tour factors out that LIV’s success to date contradicts its monopsony allegations, given what number of gamers it has been capable of entice with its thousands and thousands in assured payouts. Additionally anticipate the PGA Tour to lean on the notion that LIV Golf is the newest instance of the way in which oil-rich Gulf monarchies, just like the Kingdom of Saudi Arabia, use their huge wealth to put money into sports activities and cultural establishments in hopes of sanitizing their status for human rights abuses, a.okay.a. “sportswashing.” The PGA Tour has alleged that LIV Golf is liable for its failure to attach with golf audiences due to their distaste for affiliation with the Saudis.

As well as, the PGA Tour lodged a counterclaim in opposition to LIV Golf for tortious interference with contract in luring away Tour golfers with false guarantees of continued entry to Tour occasions, via antitrust litigation if essential. In response to the counterclaim, LIV knew full nicely that by suspending members who play for conflicting occasions with out permission, the Tour neither engaged in anticompetitive conduct nor violated its personal guidelines. LIV’s duplicity is allegedly exemplified by the truth that its personal multiyear contracts impose way more restrictive obligations than the PGA Tour, together with an absolute ban on collaborating in conflicting occasions with no risk of getting an exemption.

Pretrial Discovery and Including LIV’s Saudi Backers to the Lawsuit

Primarily based on the urgency expressed in LIV Golf’s pleadings, District Choose Freeman set an bold litigation schedule, initially calendaring the trial date for January 2024, breakneck pace for an antitrust lawsuit that examines a whole business. Pretrial discovery beneath permissive U.S. federal courtroom guidelines has proceeded, with oversight delegated to Justice of the Peace Choose Susan Van Keulen. And he or she has been saved busy as the method has been bedeviled by disputes over confidentiality demands²⁰, the proper scope of discovery requests, ²¹ and access to discovery from non-parties.²² At one level, LIV Golf tried to subpoena high-profile members of Augusta Nationwide Golf Membership, the host of the Masters Event, alleging they have been doing the PGA Tour’s soiled work by making an attempt to affect U.S. authorities officers to not examine the Tour. Amongst these named within the Augusta subpoena was former U.S. Secretary of State Condoleezza Rice. Choose Van Keulen quashed that subpoena as overly burdensome.²³

Against this, Choose Van Keulen upheld a non-party subpoena that the PGA Tour served on the Saudi PIF and its governor, Yasir Al-Rumayyan.²⁴ The Saudis hotly contested the subpoena as a violation of the U.S. International Sovereign Immunities Act (“FSIA”), which is designed to protect worldwide comity by limiting the jurisdiction of U.S. courts over international governments.²⁵ Choose Van Keulen rejected that argument, discovering that, though PIF and its governor are brokers of the Saudi authorities, they’ve been sufficiently concerned within the founding, funding, oversight, and operations of LIV Golf that they’re topic to non-party discovery beneath the “industrial exercise” exception to the FSIA.²⁶ On reconsideration, Choose Freeman affirmed that ruling,²⁷and the Saudi events at the moment are interesting to the Ninth Circuit Courtroom of Appeals.

Regardless of these discovery hiccups, the PGA Tour has realized sufficient about Saudi involvement in LIV Golf that it amended its counterclaim so as to add the PIF and Al-Rumayyan as defendants who must also be held answerable for tortious interference with contract. The courtroom accepted the amended pleading,²⁸topic to a Saudi movement to dismiss these claims, once more primarily based on FSIA immunity. The PGA Tour will little question once more argue the Saudis should undergo the courtroom’s jurisdiction beneath the FSIA’s “industrial exercise” exception, and its possibilities look good given the sooner ruling that approved non-party discovery in opposition to the Saudis.

Saudi resistance to the courtroom’s jurisdiction is grounded in its strict secrecy legal guidelines which punish by imprisonment those that reveal the confidential workings of presidency, even when compelled to take action by authorized course of. The Saudis might also be experiencing some purchaser’s regret right here, having miscalculated once they determined to fund the antitrust lawsuit within the first place, not realizing how deep they might be dragged into the muck of American adversarial litigation. Permissive U.S. discovery guidelines additionally threat unearthing particulars about different Saudi investments, and maybe the Kingdom’s makes an attempt to affect U.S. politics. If the Saudis are held topic to U.S. courtroom jurisdiction, both to offer non-party discovery and/or straight defend in opposition to the counterclaim, their incentives for settling this case multiply.

The Way forward for the Lawsuit and Skilled Golf

Due to delays in discovery, particularly from the Saudi entities, Choose Freeman has now vacated the January 2024 trial date, and focused Might 2024 as an alternative. In the meantime, depositions (pretrial examinations of witnesses beneath oath) have begun, and counsel anticipates some 80 witnesses will in the end be deposed, together with {many professional} golfers, whether or not or not named as events within the lawsuit. As soon as discovery is concluded, the pretrial evidentiary document will tee up abstract judgment motions, by which the events will every try to persuade the courtroom that they’re entitled to judgment as a matter of regulation and might dispense with a jury trial not less than as to some points and claims.

Additional slippage within the trial date appears inevitable, particularly in mild of the Saudi resolution to contest the courtroom’s jurisdiction over it each as non-party deponents within the antitrust go well with and as defendants within the Tour’s tortious interference counterclaim. LIV Golf sought to maintain its antitrust claims transferring ahead by asking the district courtroom to bifurcate the counterclaim and check out it individually at a later date. As a result of each units of claims require overlapping proof and witnesses, the courtroom denied this request as a matter of judicial economic system.

One doable end result of the lawsuit is that LIV Golf and the PGA Tour negotiate a settlement that gives for co-existence. However a big barrier can be the difficulty of reinstating LIV golfers who’ve pocketed Saudi riches, as they’ve generated a lot resentment among the many golfers who stayed loyal to the Tour. One other obstacle to settlement is tips on how to effectuate co-existence of the 2 golf circuits with out participating in cartel-like conduct that may spawn new antitrust threat.

In the meantime, the world {of professional} golf strikes ahead. Past responding to the lawsuit, the PGA Tour has had to reply to the brand new aggressive atmosphere. And its response to some extent refutes the necessity for antitrust treatments to thwart the Tour from persevering with to use its alleged monopoly energy. To retain its members who have been being provided large paydays by LIV Golf, the PGA Tour has made sweeping adjustments to its schedule, construction, and compensation. Starting with the 2022-23 season, PGA Tour members and different exempt gamers are assured $500,000 in opposition to earnings, whether or not or not they make a “reduce” in any match. This quantity is just not a wage, however slightly a base degree which supplies $500,000 in opposition to any prize cash earned that yr, to defray the bills of competing on the Tour. The Tour additionally expanded its Participant Influence Program, which debuted in 2021, to award bonuses totaling over $100 million to the 20 hottest gamers for reinforcing fan engagement and publicity.

Beginning in 2024, the PGA Tour is creating eight designated occasions with restricted fields, no cuts, and $20-million purses to carry the highest gamers collectively extra typically—and reward them extra handsomely. It’s structuring the occasions so that each one Tour members may have methods to play their manner in, to retain the depth and aggressive integrity that the Tour claims differentiates it from LIV’s 54-hole, no-cut occasions, and assured salaries. Little question the Tour will proceed to evolve, with each new technique developed beneath the shadow of antitrust and each new enterprise apply designed partially for the way it will play to an antitrust jury.

This text was first printed on the LawInSport weblog. The unique is offered to view here.

Written by: Jodi S. Balsam
Jodi is Professor of Scientific Legislation and Director of Externship Applications at Brooklyn Legislation Faculty

¹ Anushree Dinesh Burad, ‘LIV Golf wage: How a lot do golfers receives a commission?’, SportsKeeda, printed on 7 March 2023, https://www.sportskeeda.com/golf/liv-golf-salary-how-much-golfers-get-paid (final accessed 10 April 2023)
² Adam Kilgore & Matt Bonesteel, ‘PGA Tour suspends gamers in Saudi-backed occasion as golf’s discord deepens’, Washington Publish, printed on 9 June 2022, https://www.washingtonpost.com/sports/2022/06/09/pga-suspension-liv-golfers/ (final accessed 10 April 2023)
³ Grievance in Mickelson v. PGA Tour, Inc., 5:22-CV-04486 (N.D.Cal. Aug. 3, 2022) (case since re-captioned Jones v. PGA Tour, Inc.), https://www.law360.com/articles/1518020/attachments/0 (final accessed 10 April 2023).
⁴ Carola Binney, ‘Teeing Up For A Competitors Lawsuit? The PGA Tour’s Refusal To Launch LIV Golf Invitational Hopefuls’, LawInSport, printed on 7 June 2022, https://www.lawinsport.com/topics/item/teeing-up-for-a-competition-lawsuit-the-pga-tour-s-refusal-to-release-liv-golf-invitational-hopefuls (final accessed 10 April 2023)
⁵ See typically 2022-2023 PGA Tour Participant Handbook (as an example, Regulation V.A. and V.B. of the 2022-2023 PGA Tour Event Laws), https://qualifying.pgatourhq.com/static-assets/uploads/2022-2023-PGA-TOUR-HBandRegs-DEC%202022.pdf (final accessed 10 April 2023)
⁶ Regulation V.A.3. of the 2022-2023 PGA Tour Event Laws, accessible right here: https://qualifying.pgatourhq.com/static-assets/uploads/2022-2023-PGA-TOUR-HBandRegs-DEC%202022.pdf (final accessed 11 April 2023)
⁷ ‘Dustin Johnson confirms PGA Tour resignation and Ryder Cup ineligibility: ‘LIV format is true check’, Sky Sports activities, printed on 6 August 2022, https://www.skysports.com/golf/news/12176/12629313/dustin-johnson-confirms-pga-resignation-and-ryder-cup-illegibility-liv-format-is-true-test (final accessed 10 April 2023)
⁸ Joel Beall, ‘What LIV Golf’s TV deal means’, Golf Digest, printed on 21 January 2023, https://www.golfdigest.com/story/liv-golf-tv-deal-beall-2023 (final accessed 10 April 2023)
⁹ In entrance of Sport Resolutions, an unbiased non-public dispute decision tribunal. See Poulter, Jauregui and Harding v PGA European Tour, (Sport Resolutions, April 3, 2023), https://www.sportresolutions.com/decisions/view/golfers-v-pga-european-tour (final accessed 10 April 2023)
¹⁰ Anushree Dinesh Burad, ‘LIV Golf wage: How a lot do golfers receives a commission?’, SportsKeeda, printed on 7 March 2023, https://www.sportskeeda.com/golf/liv-golf-salary-how-much-golfers-get-paid (final accessed 10 April 2023)
¹¹Homero De la Fuente & Jacob Lev, ‘Phil Mickelson, 10 different LIV golfers file antitrust lawsuit in opposition to PGA Tour’, CNN, printed on 3 August 2022, https://edition.cnn.com/2022/08/03/golf/liv-golfers-sue-pga-tour-spt-intl/index.html (final accessed 10 April 2023)
¹² Grievance in Mickelson v. PGA Tour, Inc., 5:22-CV-04486 (N.D.Cal. Aug. 3, 2022) (case since re-captioned Jones v. PGA Tour, Inc.), https://www.law360.com/articles/1535281/attachments/0.
¹³15 U.S.C. § 2.
¹⁴15 U.S.C. § 1.
¹⁵ Mickelson v. PGA Tour, Inc., No. 22-CV-04486-BLF, 2022 WL 3229341 (N.D. Cal. Aug. 10, 2022).
¹⁶ The LIV golfers who deserted the lawsuit didn’t abandon the LIV Golf tour and proceed to play in that circuit, with no entry to PGA Tour occasions. And they’re nonetheless thought-about witnesses within the antitrust litigation and must flip over paperwork and sit for depositions.
¹⁷ Amended Grievance in Jones v. PGA Tour, Inc., (N.D. Cal. Aug. 26, 2022), https://www.law360.com/articles/1528971/attachments/0
¹⁸ An ‘Reply’ refers back to the formal written assertion by a defendant in a civil case that responds to a criticism, articulating the grounds for protection. Learn extra right here: https://www.uscourts.gov/glossary (final accessed 10 April 2023)
¹⁹Reply and Counterclaim in Jones v. PGA Tour, Inc. (N.D. Cal. Sept. 28, 2022), https://www.law360.com/articles/1535281/attachments/0
²⁰ Alex Miceli, ‘Choose Guidelines That PGA Tour Can Depose LIV Golf and Its Leaders’, Sports activities Illustrated, printed on 17 February 2023, https://www.si.com/golf/news/judge-rules-that-pga-tour-can-depose-liv-golf-and-its-leaders
²¹ Alex Miceli, ‘LIV Golf Lands a Authorized Win vs. PGA Tour in Battle for Data’, Sports activities Illustrated, printed on 25 October 2022, https://www.si.com/golf/news/liv-golf-lands-legal-win-vs-pga-tour-in-battle-for-information
²²Doug Ferguson, ‘Choose denies LIV plea to develop discovery to Augusta members’, Related Press, printed on 31 January 2023, https://apnews.com/article/sports-legal-proceedings-us-department-of-justice-tom-cotton-condoleezza-rice-f418ae0b51f47bbc8778bd0382453db3
²³Order in Jones v. PGA Tour, Inc., No. 22-CV-04486-BLF (N.D. Cal. Jan. 30, 2023), https://www.law360.com/articles/1570824/attachments/0 (final accessed 10 April 2023); Doug Ferguson, ‘Choose denies LIV plea to develop discovery to Augusta members’, Related Press, printed on 31 January 2023, https://apnews.com/article/sports-legal-proceedings-us-department-of-justice-tom-cotton-condoleezza-rice-f418ae0b51f47bbc8778bd0382453db3
²⁴ Jones v. PGA Tour, Inc. (N.D. Cal. Feb. 9, 2023), https://www.law360.com/articles/1577296/attachments/0
²⁵ 28 U.S.C. § 1602 et seq. The standing of the PIF as a authorities arm could show to be a difficulty within the UK in relation to the PIF’s possession of Newcastle United. Whereas taking on Newcastle, the PIF reportedly supplied ensures that it’s distinct from the Saudi authorities, ensures which can be now void as they themselves have argued the other within the US courts.
²⁶ 28 U.S.C. § 1605(a).
²⁷ Order in Jones v. PGA Tour, Inc., No. 22-CV-04486-BLF (N.D. Cal. April 6, 2023), https://www.law360.com/articles/1594786/attachments/0
²⁸ Jones v. PGA Tour, Inc., No. 22-CV-04486-BLF, 2023 WL 2173417 (N.D. Cal. Feb. 21, 2023).

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Brooklyn Sports activities & Leisure Legislation Weblog

The PGA Tour’s Monetary and Regulatory Mannequin

How Does LIV Golf Differ from the PGA Tour

Different Individuals Within the Skilled Golf Ecosystem

The Antitrust Lawsuit Early Phases

PGA Tour Goes on the Offensive

Pretrial Discovery and Including LIV’s Saudi Backers to the Lawsuit

The Way forward for the Lawsuit and Skilled Golf

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SCRIPTGUION

The PGA Tour’s Monetary and Regulatory Mannequin

How Does LIV Golf Differ from the PGA Tour

Different Individuals Within the Skilled Golf Ecosystem

The Antitrust Lawsuit Early Phases

PGA Tour Goes on the Offensive

Pretrial Discovery and Including LIV’s Saudi Backers to the Lawsuit

The Way forward for the Lawsuit and Skilled Golf

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