1905 alone from college football games.

Anyway, back in 2021, the NCAA regulated not just safety standards, but how much compensation universities could provide student-athletes.

Universities could offer undergraduate scholarships up to the full cost of attendance, and there were a few narrow pathways which schools could use under NCAA rules to compensate players.

Some were related to education, and some were unrelated to education and incidental to athletic performance.

The students alleged that the NCAA restrictions on compensation functioned as a grievance to restrict compensation in violation of Section 1 of the Sherman Act.

At the district court level, the NCAA did not contend that its members agreed to compensation limits, that they punished violators, or that its compensation limits affected interstate commerce.

But the case at the district level was narrowly focused on whether NCAA compensation restrictions were an unreasonable restraint of trade, and the court used a rule of reason analysis.

Emma, do you want to talk about the concurring opinion?