MLW Media LLC v. World Wrestling Entertainment, Inc.

Background

MLW Media LLC alleged that it competes with World Wrestling Entertainment, Inc. (WWE) and others for distribution channels for professional-wrestling content. MLW alleged that WWE pressured executives at VICE TV and Tubi, causing VICE to stop pursuing new MLW programming and Tubi to terminate an agreement with MLW.

MLW asserted claims for intentional interference with contractual relations, intentional interference with prospective economic relations, violation of Section 2 of the Sherman Antitrust Act, and violation of California’s Unfair Competition Law. The Sherman Act claim was the only claim supporting original federal subject-matter jurisdiction.

Motion to Dismiss

WWE moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not plausibly state a claim for relief. WWE argued that MLW had not plausibly alleged a relevant market, monopoly power, or antitrust injury.

The court held that MLW had not plausibly alleged a relevant product market. MLW proposed a national market for selling broadcasting rights for professional-wrestling programs to networks, cable, and streaming services. But the complaint did not provide enough facts about the market’s characteristics, including whether other sports-entertainment or media content could be reasonably interchangeable substitutes. The complaint also used multiple descriptions of the proposed market, making its boundaries unclear.

The court therefore granted WWE’s motion to dismiss MLW’s Sherman Act claim. The court also stated that MLW’s allegations concerning monopoly power and antitrust injury appeared unlikely to withstand a motion to dismiss as currently pleaded, but the court’s stated basis for dismissing the Sherman Act claim was the inadequate relevant-market allegations.

State-Law Claims and Leave to Amend

After dismissing the Sherman Act claim, the court held that it lacked subject-matter jurisdiction over MLW’s remaining California-law claims. The court dismissed the claims for intentional interference with contractual relations, intentional interference with prospective economic relations, and violation of the Unfair Competition Law.

The court found that additional allegations might cure the identified deficiencies and granted MLW leave to amend. Any amended complaint had to be filed within 21 days of the order’s issuance.

Other Motions and Disposition

Because the court resolved the motion to dismiss, it denied as moot WWE’s motion for a protective order staying discovery and its administrative motion for a discovery-status conference. The court stayed discovery until further court order.

The order’s final dispositions were: WWE’s motion to dismiss was granted with leave to amend; WWE’s motion for a protective order was denied as moot; and WWE’s administrative motion for a status conference regarding the discovery schedule was denied as moot.