Fair Pay to Play Act

And Justice Kavanaugh warned ominously in his concurrence that the compensation rules, which were not at issue in that case, looked an awful lot like naked price fixing.

But after all, some state NIL rules began to appear, beginning with California's 2019 Fair Pay to Play Act, states rapidly enacted laws protecting college athletes' ability to earn money for their NIL.

By early 2022, 28 states permitted some form of NIL compensation.

In July of 2021, the NCAA responded by suspending its restrictions on third-party NIL compensation while continuing to prohibit traditional pay-for-play arrangements.