2 1 and New York, NY, for Amici Curiae 14 Antitrust, 2 Sports Law, and Economics Professors, in support of 3 Plaintiff-Appellant. 4 5 LOHIER, Circuit Judge:

6 Soccer, also known as “the beautiful game,” unites the world in shared

7 competition. This case, by contrast, concerns an allegedly anticompetitive

8 policy that restricts access to the game by prohibiting soccer leagues and

9 teams from playing official season games outside of their home territory. 10 Relevent Sports, LLC (“Relevent”), a U.S.-based soccer promoter, alleges that 11 the Fédération Internationale de Football Association (“FIFA”) and the United 12 States Soccer Federation, Inc. (“USSF”) adopted and enforced this geographic 13 market division policy (“2018 Policy”) in violation of Section 1 of the Sherman 14 Antitrust Act and Sections 4 and 16 of the Clayton Antitrust Act. 15 The United States District Court for the Southern District of New York 16 (Caproni, J.) determined that Section 1 required Relevent to present either 17 direct or circumstantial evidence of an “antecedent ‘agreement [among 18 horizontal competitors] to agree to vote a particular way’ to adopt such a 19 policy.” Special App’x 33 (alteration in original). After concluding that 20 Relevent failed to allege that the 2018 Policy itself stemmed from or

3 1 constituted direct evidence of such a prior agreement among the Defendants,

2 the District Court dismissed Relevent’s complaint for failure to state a claim.

3 We disagree with the District Court’s conclusion. Relevent plausibly

4 alleges that the 2018 Policy reflects a contractual commitment of head-to-head

5 competitors to restrict competition. Because Relevent’s complaint challenges

6 the 2018 Policy itself “as violative of the antitrust laws,” the “promulgation of

7 [the policy] . . . constitute[s] direct evidence of § 1 concerted action.” N. Am.

8 Soccer League v. U.S. Soccer Fed’n, 883 F.3d 32, 41 (2d Cir. 2018) (“NASL”);

9 see Associated Press v. United States, 326 U.S. 1, 12 (1945). No further 10 allegation of an agreement is necessary. In holding that no inference of 11 concerted activity can be drawn from the “promulgation” of the 2018 Policy, 12 the District Court’s decision conflicts directly with this core principle. The 13 judgment of the District Court is thus VACATED and the matter is 14 REMANDED for further proceedings consistent with this opinion.

4 1 BACKGROUND 1

2 We start with an overview of the governance structure of international

3 soccer. FIFA, a private membership-based association comprised of over 200

4 national associations, is the well-known international governing body for

5 soccer. Each national association is itself membership-based and comprised

6 of professional soccer leagues and teams. FIFA’s legislative body, the FIFA

7 Congress, includes representatives from every national association in the

8 world and adopts and amends the FIFA Statutes, which contain many of

9 FIFA’s rules and policies. A smaller entity within FIFA, the FIFA Council, 10 “has authority to interpret the FIFA Statutes and to adopt rules and policies 11 not specifically addressed in the FIFA Statutes.” App’x 502. 12 National associations represent their members in FIFA decision-making 13 and agree to “comply fully with the Statutes, regulations, directives and 14 decisions of FIFA bodies at any time.” App’x 500–01. In turn, the national 15 associations require their members to agree to comply with these same rules 16 and policies. USSF is the FIFA-authorized national association for the United

1These facts are drawn from the amended compl