2 Divisional regulations which have the purpose and effect of protecting the monopoly position of its commercial business partner, Major League Soccer (“MLS”), in the relevant market for top- tier men’s professional soccer l eagues located in the U.S. and Canada. The USSF has declared this top tier market to be “Division I.” 3.

Below the top tier of men’s professional soccer in the U.S. and Canada, the USSF has also entered into contracts, combinations and conspiracies in restraint of trade which, if not enjoined, will grant a monopoly position in the market for second-tier men’s professional soccer leagues located in the U.S. and Canada to the United Soccer League (“USL”). The USL has embraced its “minor league” status below that of MLS and has entered into various commercial arrangements with MLS to serve as its reserve league, with no possibility of USL ever challenging MLS’s dominance in the top tier. The USSF has declared this second-tier m arket to be “Division II.” 4.

By promulgating a changing portfolio of so-called “Professional League Standards” and regulations to protect MLS, and now USL, from competition, the USSF enriches itself and protects MLS as the o nly top-tier Division I men’s professional soccer league located in the U.S. and Canada, immune from competition from new entrants and potential rival leagues even though the USSF is a private organization and has no legal authority to confer immunity from competition to anyone. 5.

Plaintiff North American Soccer League (“NASL”) is a men’s professional soccer league located in the U.S. and Canada that has sought to compete with MLS as a top-tier professional soccer league, and whose clubs have frequently defeated MLS clubs in periodic matchups. However, its efforts to compete with MLS in the top tier of professional soccer have been thwarted by the USSF, which has applied its Professional League Standards in an