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| | FOR THE DISTRICT OF NEW JERSEY | | FOR THE DISTRICT OF NEW JERSEY |
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| − | | + | ______, as Parents of student _______________, |
| − | Parents of student _______________, | |
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| | Plaintiff, | | Plaintiff, |
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| | DEFENDANT AND CONSPIRATORS | | DEFENDANT AND CONSPIRATORS |
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| − | 3. The NJSIAA is the <describe association and its legal status>. | + | 3. The NJSIAA is a trade organization of high schools that does business in New Jersey by regulating sporting events of its member schools. |
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| | 4. Whenever this Complaint refers to any act, deed, or transaction of the NJSIAA, it means that the NJSIAA engaged in the act, deed, or transaction by or through its officers, directors, employees, agents, or other representatives while they actively were engaged in the management, direction, control, or transaction of its business or affairs. | | 4. Whenever this Complaint refers to any act, deed, or transaction of the NJSIAA, it means that the NJSIAA engaged in the act, deed, or transaction by or through its officers, directors, employees, agents, or other representatives while they actively were engaged in the management, direction, control, or transaction of its business or affairs. |
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| | TRADE AND COMMERCE | | TRADE AND COMMERCE |
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| − | 6. The NJSIAA conducts the <describe sports programs>. <sports programs> is a service industry that, in ____, involved approximately ______ in revenue. The NJSIAA's accrediting activities and operations involve or affect the interstate flow of, and have a substantial effect on, interstate commerce. | + | 6. The NJSIAA's accrediting activities and eligibility decisions involve or affect the interstate flow of, and have a substantial effect on, interstate commerce by regulating sporting events throughout New Jersey that attracts millions of spectators spending millions of dollars annually. |
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| | + | 7. In addition, the NSJIAA's accrediting activities and eligibility decisions involve or affect the interstate flow of, and have a substantial effect on, interstate commerce by determining who can compete for lucrative college scholarships, which are worth up to $100,000 and more to each student at colleges located in all 50 states. |
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| | + | 8. The assets of the NJSIAA, as of _______, was $______________, in reflection of the big business of high school sports in New Jersey. |
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| | IV. | | IV. |
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| | BACKGROUND | | BACKGROUND |
| | ... | | ... |
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| | + | market power. |
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| | VI. | | VI. |
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| | REQUESTED RELIEF | | REQUESTED RELIEF |
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| − | Plaintiff requests permanent injunctive relief enjoining Defendant and other conspirators from engaging in further violations of Section 1 of the Sherman Act. | + | Plaintiff requests that Defendant, its members, officers, agents, servants, employees, attorneys and all persons in active concert or participation with them, pending the final hearing and decision in this action, are enjoined from applying its By-laws, rules, regulations or interpretations in any manner so as to prevent or interfere with, or from taking any other action, directly or indirectly, to prevent or interfere with Plaintiff from playing tennis on his local public high school team. |
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| | + | Plaintiff requests that Defendant, its members, officers, agents, servants, employees, attorneys and all persons in active concert or participation with them, be permanently enjoined from applying its By-laws, rules, regulations or interpretations in any manner so as to prevent or interfere with, or from taking any other action, directly or indirectly, to prevent or interfere with Plaintiff from playing tennis on his local public high school team. |
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| | Dated: ________ | | Dated: ________ |