NFL Players Association Files Suit Against Owners Claiming Salary Suppression

From the Complaint:

1. This proceeding arises from a conspiracy. Pursuant to the SSA, the NFL and the Owners explicitly agreed that the 2010 season would not be subject to a salary cap and that they would not engage in any prohibited collusion or circumvention of the SSA. The NFL and the Owners, however, engaged in a secret, recently-revealed collusive andCASE 4:92-cv-00906-DSD-SPMS Document 703 Filed 05/23/12 Page 2 of 20

circumventing agreement, whereby each of the 32 Clubs agreed to suppress player salaries – including by imposing a secret $123 million per-Club salary cap for that uncapped 2010 season.

2. Information about this conspiracy did not come to light until on or about March 12, 2012, when it was revealed in the media that four of the 32 Clubs (Washington Redskins, Dallas Cowboys, Oakland Raiders, and New Orleans Saints) did not fully abide by secret NFL rules to suppress player salaries in 2010. New York Giants Owner John Mara – who is Chair of the NFL Management Council Executive Committee (a.k.a., the CEC) – subsequently confirmed the existence of the conspiracy in his statements to the media regarding penalties imposed by the NFL on those four Clubs. The NFLPA and the players also later learned that, according to internal NFL calculations, those four Clubs did not adhere to the league-wide conspiracy, at least not fully, in exceeding the secret salary cap during the uncapped 2010 season by the following amounts: Redskins: $102,833,047; Cowboys: $52,938,774; Raiders: $41,914,060; Saints: $36,329,770.

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