Directv, LLC v. Nexstar Media Group, Inc.

CourtDistrict Court, S.D. New York
DecidedMarch 20, 2024
Docket1:23-cv-02221
StatusUnknown

This text of Directv, LLC v. Nexstar Media Group, Inc. (Directv, LLC v. Nexstar Media Group, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Directv, LLC v. Nexstar Media Group, Inc., (S.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -----------------------------------------------------------X : DIRECTV, LLC, : : Plaintiff, : : 23-cv-2221 (PKC) -against- : : NEXSTAR MEDIA GROUP, INC., : OPINION AND ORDER MISSION BROADCASTING, INC. and : WHITE KNIGHT BROADCASTING, INC., : :

: Defendants. -----------------------------------------------------------X

CASTEL, Senior District Judge.

Plaintiff DIRECTV, LLC (“DIRECTV”) describes itself as the country’s leading satellite television provider. Defendants, Nexstar Media Group Inc. (“Nexstar”), Mission Broadcasting, Inc. (“Mission”), and White Knight Broadcasting, Inc. (“White Knight”) (collectively “Defendants”), are a group of broadcasters that own popular television networks in various local markets. A retransmission agreement or “RCA” permits a television provider such as DIRECTV to retransmit programming content furnished by broadcasters in exchange for a fee. In 2022, DIRECTV did not renew its RCA with Mission and White Knight because it considered the prices demanded to be unreasonable. With no RCA in place, there were content “blackouts” for nearly 1 million DIRECTV subscribers and a loss of thousands of customers who terminated their subscriptions with DIRECTTV. DIRECTV claims that all three Defendants conspired to fix prices for RCAs and it suffered losses as a result. DIRECTV now brings this action for violations of the federal antitrust laws, and for related contract and tort claims arising under New York law. Presently before the Court is Defendants’ motion to dismiss the Complaint pursuant to Rule 12(b)(1) and 12(b)(6), Fed. R. Civ. P. ECF 52. For the reasons that follow, the Court concludes that the Complaint adequately alleges DIRECTV’s Article III standing but does not plausibly allege standing under the antitrust

laws. Specifically, DIRECTV did not enter into an RCA with Mission or White Knight which would have required it to pay what it alleges to be “supracompetitive” fees. Compl. ¶ 2, ECF 1. Because the RCAs were not renewed, DIRECTV customers experienced “blackouts” that caused them to cancel or not renew their services causing DIRECTV to suffer a profit loss. DIRECTV cannot allege that the injury is of the type the antitrust laws were intended to prevent and that it flows from the anticompetitive nature of Defendants’ conduct. Also, on the facts alleged, the Court concludes that DIRECTV lacks antitrust standing because it would not be an efficient enforcer of the antitrust laws. The Court declines to exercise supplemental jurisdiction over Plaintiff’s remaining state law claims and dismisses them without prejudice. BACKGROUND

The following facts are drawn from Plaintiff’s Complaint and are taken as true for the purpose of resolving the instant motions. Faber v. Metro. Life Ins. Co., 648 F.3d 98, 104 (2d Cir. 2011). I. The Parties Nexstar, White Knight, and Mission are broadcasters that own local affiliates of popular television networks in various local markets, called “designated market areas” (“DMAs”). Compl. ¶¶ 31–33. Defendants each own stations affiliated with “Big-4” networks—ABC, CBS, NBC, and Fox—that acquire rights to national programming (like sports) and create content of their own (like local news). Id. ¶ 37. Big-4 stations are typically the highest ranked in terms of audience share and ratings in each DMA, primarily due to their combination of high-value content such as sports, primetime shows, local news, and events such as The Oscars. Id. ¶ 80. Plaintiff DIRECTV is a multichannel video programming distributor (“MVPD”) that provides its customers with satellite and streaming access to popular broadcast television

programming. Id. ¶ 3. MVPDs regularly contract with broadcast groups, such as Defendants, to negotiate “retransmission consent agreements,” which allow MVPDs to pay a fee to transmit broadcast content from Big-4 stations to MVPD subscribers. Id. ¶¶ 4, 39. If an RCA between an MVPD and a broadcast group expires without renewal, the MVPD loses retransmission rights, and the broadcast content is “blacked out” for the MVPD’s subscribers until a new agreement is reached. Id. ¶ 62. To promote competition among broadcasters, federal regulations generally prohibit a single broadcast station group from owning, operating, or controlling more than one Big-4 station within the same DMA (known as the “Duopoly Rule”). Id. ¶ 5. If a broadcast group seeks to acquire a second Big-4 affiliate within a single DMA, it generally must divest one of its Big-4

stations to another broadcaster. Id. Federal law permits the divested and divesting stations to enter “sharing arrangements,” where one station can provide services to the other, such as common facilities or technical services, but the stations are barred from coordinating on matters such as RCA negotiations. Id. Divested stations relying on services from divesting stations are known as “sidecars,” as they must rely on the larger group for many aspects of their operations. Id. ¶ 6. In recent years, Nexstar has acquired many broadcast groups and is now the largest U.S. broadcaster, with 200 owned or operated stations in 116 markets reaching 212 million people. Id. ¶ 65. When Nexstar acquires a broadcast group which owns stations that overlap with its existing portfolio, it divests a Big-4 station to its sidecars to comply with the Duopoly Rule. Id. ¶¶ 67–74. White Knight and Mission are two such sidecars of Nexstar. Id. ¶ 66. Today, Mission owns Big-4 stations in 23 DMAs, while White Knight owns stations in two DMAs; in each of these markets, Nexstar maintains a competing Big-4 station. Id. ¶¶ 71, 73. II. DIRECTV’s RCA Renewal Negotiations with Mission and White Knight

In June 2022, DIRECTV began negotiating the renewal of its RCAs with Mission and White Knight, each of which was set to expire in August 2022 (later extended to October). Id. ¶¶ 90–91, 95. Despite federal regulations prohibiting Nexstar from coordinating with its sidecars in the RCA negotiations, DIRECTV alleges that Mission and White Knight have entered into an agreement “with Nexstar to raise prices and extract supracompetitive retransmission consent fees from DIRECTV in ‘overlap’ DMAs—those markets where both Nexstar and either Mission or White Knight each own a Big-4 station.” Id. ¶ 9. For example, DIRECTV claims that Nexstar “orchestrated a common third party,” consultant Eric Sahl, to be the common negotiator for the sidecars. Id. ¶ 11. They claim that Sahl failed to conduct independent negotiations for each of the companies, and instead coordinated terms in order to serve Nexstar’s interests. See id. ¶¶ 17–19.

Moreover, they claim that Sahl demanded fees that were “radically disproportionate to the number of stations” Mission and White Knight owned, and which were “intentionally calculated to prevent the parties from reaching an agreement.” Id. ¶¶ 97, 99. Finally, DIRECTV points to “nearly identical press releases” issued by Nexstar, Mission, and White Knight concerning their respective blackouts as evidence of collusion. Id. ¶ 106. DIRECTV avers that Nexstar had two goals in conspiring with Mission and White Knight to fix prices. First, it claims that Nexstar would benefit directly from Mission and White Knight’s increased prices.1 Id. ¶ 18. Second, and more importantly, DIRECTV claims that its contract with Nexstar was set to expire in July 2023, and that its contract renewal with Nexstar represented “DIRECTV’s largest single retransmission consent agreement in terms of total dollars paid to a broadcast station group.” Id. With an eye towards these “enormous” negotiations,

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Bluebook (online)
Directv, LLC v. Nexstar Media Group, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/directv-llc-v-nexstar-media-group-inc-nysd-2024.