House Settlement Fund Awards Damages to Former College Athletes
The House v. NCAA settlement awards $2.8 billion in damages to college athletes who competed between September 2016 and June 2025, the date Judge Wilken approved the settlement (“Damages Class Members” or “Class Members”).1[1]College Athlete Compensation, COLL. ATHLETE COMP. https://www.collegeathletecompensation.com/ (last visited Feb. 26, 2026). The $2.8 billion reflects the combined settlements in House v. NCAA and Hubbard v. NCAA. Under House, the NCAA and Power Five Conferences agreed to pay $2.57 billion in damages to Class Members barred from monetizing their NIL between 2016-2025 (Damages Class Members). See id. Under Hubbard, the NCAA and Power Five Conferences agreed to pay $200 million to Class Members who competed between 2019-2022. See id. This money compensates the athletes for the NCAA having prohibited or limited them from profiting off of their name, image, and likeness (NIL). These “back-pay” damages awards will be paid out over 10 years, with 95% of the funds allocated to football and basketball players.2[2]Bernie Dennis, Unpacking the House Settlement’s Impact on Collegiate Athletics, JACKSONLEWIS (Sept. 30, 2025), https://www.jacksonlewis.com/insights/unpacking-house-settlements-impact-collegiate-athletics-0#:~:text=The%20distribution%20framework%20of%20all,5%25%20to%20the%20other%20sports. Individual awards will vary by sport, with football and men’s basketball athletes from power conferences projected to receive an average of $135,000, compared to approximately $30,000 for their women’s basketball counterparts.3[3]Dan Murphy, Court Filing Reveals Terms of NCAA Antitrust Lawsuits Settlement, ESPN (Jul. 26, 2024), https://www.espn.com/college-sports/story/_/id/40649389/ncaa-antitrust-lawsuits-settlement-filed-federal-court.
Over 100,000 Damages Class Members will receive a “back-pay” award from the settlement fund.4[4]Associated Press, 153 NCAA Rules Had to Be Eliminated to Clear the Way for the House Settlement. Numbers to Know, FOX SPORTS (June 6, 2025), https://www.foxsports.com/articles/wcbk/153-ncaa-rules-had-to-be-eliminated-to-clear-the-way-for-the-house-settlement-numbers-to-know (reporting that 101,935 House Class Members submitted a claim form or updated their payment information entitling them to a damages award). However, appeals of the House settlement have paused distribution of these awards. Even assuming the Ninth Circuit resolves the appeals by 2027 and upholds the damages settlement, distribution of funds to Damages Class Members is likely to extend through 2037.
Amid uncertainty about whether and when settlement funds will ultimately be distributed, third-party claim buyers began to make unsolicited contact with former college athletes offering to buy their damages claims at a discount. This article explains the House damages settlement and offers Class Members practical guidance for evaluating third-party claim buyer offers. It also connects interested parties to the Brooklyn Law School Sports Law Clinic for a free consultation on evaluating third-party claim buyouts.
Third-Party Claim Buyout Offers in House – What Are They?
Third-party claim buyers offer recipients of settlement awards an upfront discounted cash payment in exchange for assuming (a) the rights to future payments from the settlement fund and (b) the risk of delay or denial of the claims.5[5]In re: College Athlete NIL Litigation (House) v. NCAA, SYCAMORE GROVE CLAIMS GRP., LLC (last visited Feb. 24, 2026), https://www.sycamoregroveclaims.com/nil-settlement. Beginning in 2025, as payment of the $2.8 billion House settlement remained delayed, third-party claim buyers began capitalizing on Damages Class Members’ desire for immediate funds.
One such company is Sycamore Claims Group, LLC, a private investment firm that specializes in purchasing rights to settlement payments.6[6]Sycamore Grove Has Purchased Well Over $100 Million of NIL Settlement Claims from Over 1,000+ NCAA Athletes, SYCAMORE GROVE CLAIMS GRP., LLC https://www.sycamoregroveclaims.com/ (last visited Feb. 26, 2026). Other companies, such as NCAACreditor, offer Class Members a streamlined process to sell their claims, advertising a competitive cash offer within 12 hours of submitting preliminary settlement information and payment within 24 hours of finalizing the transaction. See Convert Your NCAA Settlement Into Immediate Cash, NCAA CREDITOR https://www.ncaacreditor.com/?utm_source=ig&utm_medium=social&utm_content=link_in_bio&fbclid=PAZXh0bgNhZW0CMTEAc3J0YwZhcHBfaWQMMjU2MjgxMDQwNTU4AAGnKLLtzv4i0MzPlGdTe2GWY1EpAcBd6HmlsyzF8QNs8gPuBioCMsnyg6cEO00_aem_2nt4u6fll1aIT28SP6YuVw (last visited Feb. 26, 2026). Sycamore contacted Class Members through LinkedIn, offering “a negotiated cash amount upfront” in exchange for their “eventual settlement payment.”7[7]Email From Race Johnson, to Aidan J. Flannery, Samantha H. Lovett (Jan. 30, 2026, 3:02 PM EST) (on file with author). Class Counsel then filed a motion with the court to prohibit third-party claim buying, citing administrative burdens and tax implications for Class Members and expressing concern about predatory conduct.8[8]Plaintiff’s Renewed Motion for a Prospective Order Concerning Third-Party Claims Buyout Service, In Re College Athlete NIL Litigation, No. 20-cv-03919 at 5 (N.D. Cal. Sept. 5, 2025), ECF No. 1028. https://storage.courtlistener.com/recap/gov.uscourts.cand.360907/gov.uscourts.cand.360907.1028.0.pdf. Recognizing both the potential benefits and risks associated with the purchase of Class Members’ settlement claims, Judge Wilken approved these transactions subject to mandatory disclosures and protections. Specifically, the Court established five criteria to regulate third-party claim buyout services:
First, all third-party claim buyers must “fully disclose the potential tax implications of the settlement distributions to Class Members prior to signing any contract” concerning claims in the House settlement.9[9]Order Regarding Third-Party Claims Buyout Services, In Re College Athlete NIL Litigation, No. 20-cv-03919 (N.D. Cal. Sept. 16, 2025), ECF No. 1047 at 2. https://www.collegeathletecompensation.com/media/6203044/ncco_order_regarding_third-party_claims_buyout_services.pdf. The required disclosure, which is presented in the Order, “should be provided at least twice” – once during “the initial solicitation or marketing materials” and again “with any sale or transaction agreement . . . .”10[10]Id.
Second, Class Counsel – Hagens Berman Sobol Shapiro LLC and Winston & Strawn LLP – “will continue to monitor Third-Party Claim Buyers to ensure” compliance with the Court’s Order imposing such regulations.11[11]Order Regarding Third-Party Claims Buyout Services, In Re College Athlete NIL Litigation, No. 20-cv-03919 (N.D. Cal. Sept. 16, 2025), ECF No. 1047 at 3. https://www.collegeathletecompensation.com/media/6203044/ncco_order_regarding_third-party_claims_buyout_services.pdf.
Third, Class Counsel is required to “update the Settlement website with an FAQ regarding the potential tax implication of payments from third-party claims buying entities.”12[12]Id.
Fourth, the House settlement fund from which payment will be distributed to Class members, may only “provide direct disbursements of settlement funds…to Third-Party Claim Buyers that have completed outright purchases from Class Members . . . .”13[13]Id. Importantly, for funds to be distributed to third-party claim buyers, such purchases must be “completed prior to the exhaustion of any appeals in the case.”14[14]Id.
Fifth, with respect to the outright sales of claims, third-party claim buyers must notify the settlement fund. For “outright sales of claims completed prior to the exhaustion of any appeals,” third-party claim buyers must “promptly notify [the settlement fund] in writing within 15 days of closing the sales transaction . . . .”15[15]Id. For claims that predated the Court’s requirements, third-party claim buyers were required to provide written notice “within 15 days” of the Court’s September 16, 2025, Order.16[16]Id. These notifications must identify “both the sale and the identity of the Third-Party Claim Buyer” and include “(i) a copy of a true bull of sale and (ii) a signed indemnification form.”17[17]Order Regarding Third-Party Claims Buyout Services, In Re College Athlete NIL Litigation, No. 20-cv-03919 (N.D. Cal. Sept. 16, 2025), ECF No. 1047 at 3-4. https://www.collegeathletecompensation.com/media/6203044/ncco_order_regarding_third-party_claims_buyout_services.pdf. The purchaser of a Class Member’s claim must agree to indemnify Verita Global LLC (the claims administrator), the settlement fund, and the fund’s directors, managers, and employees from losses arising out of the sale of a claim – including disputes over a Class Members’ eligibility for payment, competing claims to the funds, or tax reporting obligations. See id.
Despite these protections against predatory claim buyouts, more detailed and practical advice is essential to help Class Members properly assess whether accepting a third-party claim buyout offer is in their best interest. Class Counsel has provided general advice regarding third-party claim buyer offers, but is not permitted to “facilitate” or “represent [athletes] in negotiating a contract sale” of their claims.18[18]In re:College Athlete NIL Litigation (House) Frequently Asked Questions, COLL. ATHLETE COMP. https://www.collegeathletecompensation.com/house-frequently-asked-questions.aspx (last visited Feb. 26, 2026). Class Members are thus left without meaningful guidance or resources to evaluate, on an individual basis, how a particular offer compares to their anticipated recovery, current financial circumstances, and tolerance for delay.
For some Class Members – particularly those in need of immediate liquidity – accepting a third-party claim buyer offer may be advantageous. For others, however, the costs of assigning their rights to the damages claim may exceed the benefits of an accelerated cash payment. Class Members need guidance tailored to their personal circumstances to properly evaluate the tax consequences, potential irrevocability, and fairness of claims buyouts.19[19]Third Party Contracts & Settlement Claims for NCAA House Class Members, HAGENS BERMAN SOBOL SHAPIRO LLP (2025), https://www.hbsslaw.com/ncaa-student-athlete-name-image-and-likeness/third-party-contracts-and-settlement-claims-for-ncaa-house-class-members#:~:text=What%20House%20Class%20Members%20Need,down%20before%20they%20are%20finalized.
Pros & Cons of Third-Party Claim Buyer Offers for Class Member Claims
Should a House Class Member sell his or her claim to a third-party claim buyer? There is no single uniform answer, and this article does not advocate for or against doing so. Rather, Class Members who are approached to sell their claims should consider the following pros and cons.
Pros:
● Cash now: The House settlement grants back pay to Division I athletes in installments over 10 years, meaning that even if payments began on the date the settlement was approved in June 2025, Class Members would not receive full payment until 2035. Appeals of the settlement to the Ninth Circuit paused distribution, and it likely won’t restart until 2027, delaying final payment to Class Members to 2037.20[20]Darren Heitner, Newsletter, Image, Likeness Vol. 143: Cash Now or Hold Out? Navigating Offers to Buy House v. NCAA Settlement Claims, LINKEDIN (Aug. 1, 2025), https://www.linkedin.com/pulse/newsletter-image-likeness-vol-143-cash-now-hold-out-offers-heitner-ysule/. Class Members may need cash now to offset financial pressures or launch their own ventures.
● Offload risk of reversal: The appeals of the House settlement primarily raise Title IX challenges to Judge Wilken’s decision, arguing that the settlement favors male athletes over female athletes.21[21]See Michael McCann, NCAA Defends House Settlement from Title IX, Opt-Out Appeal, SPORTICO (Jan. 5, 2026, 11:00 AM), https://www.sportico.com/law/analysis/2026/ncaa-house-settlement-appeal-1234880134/ (indicating that the loser to the Ninth Circuit decision could appeal to the United States Supreme Court, pushing “the litigation clock back another year or two”). While many believe that the Ninth Circuit will affirm Judge Wilken’s decision, some risk remains that the appeals court will derail the settlement and eliminate or reduce awards to Class Members.22[22]See Darren Heitner, Newsletter, Image, Likeness Vol. 143: Cash Now or Hold Out? Navigating Offers to Buy House v. NCAA Settlement Claims, LINKEDIN (Aug. 1, 2025), https://www.linkedin.com/pulse/newsletter-image-likeness-vol-143-cash-now-hold-out-offers-heitner-ysule/ (arguing that “if appeals succeed, some athletes could end up with nothing”); see Michael McCann, NCAA Defends House Settlement from Title IX, Opt-Out Appeal, SPORTICO (Jan. 5, 2026, 11:00 AM), https://www.sportico.com/law/analysis/2026/ncaa-house-settlement-appeal-1234880134/ (articulating that there is a good chance that the 9th Circuit will be deferential to Judge Wilkens’ decision); see Shehan Jeyarajah & Brandon Marcello, House v. NCAA Settlement Payments on Hold Amid Legal Challenge from Female Athletes on Title IX Grounds, CBS SPORTS (June 11, 2025, 2:28 PM), https://www.cbssports.com/college-football/news/house-v-ncaa-settlement-payments-on-hold-amid-legal-challenge-from-female-athletes-on-title-ix-grounds/.
● Offload risk of default: The House damages settlement requires the NCAA and participating DI universities to fund it. There is a marginal risk that they will be unable to do so.
Cons:
● Lowball Offers: Third-party claim buyer offers are likely to be substantially less than the future settlement payout, even taking into account the present value of the ultimate award.23[23]See id. In some cases, third-party claim buyer offers can be as low as 10%-20% of the total settlement payout. Id.
● Loss of Control: When an athlete accepts a third-party claim buyer offer and assigns or sells their claim to the third-party claim buyer, they may forfeit any and all rights to additional income or future payments they would otherwise be entitled to, but for the sale of their claim.24[24]In re: College Athlete NIL Litigation (House) Frequently Asked Questions, COLL. ATHLETE COMP. https://www.collegeathletecompensation.com/house-frequently-asked-questions.aspx (last visited Feb. 23, 2026); see also Darren Heitner, Newsletter, Image, Likeness Vol. 143: Cash Now or Hold Out? Navigating Offers to Buy House v. NCAA Settlement Claims, LINKEDIN (Aug. 1, 2025), (providing evidence that while “[t]here’s usually a short “cooling off” period—say, 10 days—to back out, but after that, it’s binding…[complicating] an athlete’s ability to reclaim control if regrets set in”).
● Tax Implications: Depending on the terms of the purchase agreement between the athlete and third-party claim buyer, the athlete may still have to pay taxes on the full original value of the claim, instead of the amount received from the third-party claim buyer, even if the athlete did not receive the full value of their original claim.25[25]In re: College Athlete NIL Litigation (House) Frequently Asked Questions, COLL. ATHLETE COMP. https://www.collegeathletecompensation.com/house-frequently-asked-questions.aspx (last visited Feb. 23, 2026). Such tax obligations may even exceed the total amount the athlete received from the third-party claim buyer.26[26]Id. Alternatively, if a third-party claim buyer payment is structured as an outright or “true” sale, the athlete would likely be taxed only on the purchase price they received under the third-party claim buyer agreement; however, the agreement would likely remove an athlete’s right to future settlement payments.27[27]Id.
Further, Class Members should consider their individual financial situation. Whether to accept a fast cash offer may depend on their current employment situation, tax bracket, outstanding debt, family obligations, or educational, business, and investment opportunities. In practice, many Class Members may not have the resources or guidance to evaluate the pros, cons, and their personal circumstances. Nor are they all equipped to read and understand lengthy buy-out contracts or negotiate for a better deal. Information is available on the House settlement website that explains the third-party claim-buying process and its legal implications.28[28]Id. Specifically, the website advises that while “Class Members have the right to sell their claims if they choose to do so…[they] may be forfeiting any and all rights to receive additional income or future payments under the settlement agreement.” Id. But all Class Members could benefit from personalized advice.
The Hypothetical House Damages Class Member and the Time Value of Money
One additional concept that Class Members need to understand to evaluate a claim buyout offer is the Time Value of Money (“TVM”). To put TVM in context, consider the following hypothetical former college athletes:
● DI athlete who played basketball from 2018 to 2022, and under the House settlement is entitled to $125,000 in back-pay damages, paid over 10 years. An investment firm reaches out over LinkedIn, offering $25,000 cash to buy the rights to the claim (20% of the settlement claim).
● DI swimmer who competed for the team from 2017-2021, and under the House settlement will receive $45,000 in installments over 10 years. A different third-party claim buyer contacts the swimmer on Instagram, offering to pay $4,500 in cash (10% of the claim).
Assuming these Class Members have no urgent immediate need for the money, should they take these deals?
Class Members can assess whether the third-party claim buyer deal makes economic sense and fairly allocates risk by calculating the present value of the future settlement payments. That is, what is the time value today of money paid tomorrow? The TVM principle recognizes that money available now is always worth more than the same amount in the future because money received today can be invested to earn interest, reduce uncertainty and risk, and anticipate inflation.29[29]Catherine Cote, Time Value of Money (TVM): A Primer, HARV. BUS. SCH. ONLINE (June 16, 2022), https://online.hbs.edu/blog/post/time-value-of-money (outlining that “TVM calculations ‘translate’ all future cash to its present value”).
TVM is calculated through a complex equation.30[30]See id. The present value formula is PV=FV/(1+i)n where FV = amount of money expected to be paid in the future, i = the interest rate, and n = number of years over which FV will be paid. Id. However, online TVM calculators are widely available.31[31]Present Value Calculator, CALCULATOR SOUP: ONLINE CALCULATORS https://www.calculatorsoup.com/calculators/financial/present-value-calculator.php (last visited Feb. 23, 2026). They answer the question, “What do I need to invest today to have a specific sum of money at a future date?” From the perspective of a House Class Member, TVM calculators answer the question, “What is the value today of the future settlement payments promised to me over the next 10 years?” Class Members who know the present value of their damages awards can better assess the fairness of a third-party claim buyout offer.
Consider the hypothetical Class Members above who are entitled to future settlement payments of $125,000 to the basketball player and $45,000 to the swimmer. The chart below shows the results of plugging those numbers into a TVM calculator, using a 10-year payment period, and assuming a 4% interest rate.
| Hypothetical House settlement award | TVM calculation (present value today) | Hypothetical third-party buyout offer |
| $125,000 | $83,845.76 | $25,000 |
| $45,000 | $30,184.47 | $4,500 |
As the chart plainly demonstrates, the third-party claim buyer has significantly understated the present value of the House settlement awards. The claim buyer should be offering far more cash today, absent a substantial risk that the House settlement fund will not eventually pay on those claims. The claim buyer might argue that the lowball offers reflect the risk that the Ninth Circuit will reverse or that the NCAA and DI universities will not come up with the settlement funds. But those risks are widely considered negligible and do not justify such a steep discount on the present value of the Class Members’ awards.
These Class Members may still want to take the cash now, but knowing the present value of their ultimate settlement award could help them negotiate a higher buyout from the third-party claim buyer.
So, Now What?
Each Class Member is uniquely situated. Agreeing to sell a claim to a third-party claim buyer may be hugely beneficial for one Class Member and deprive another of meaningful compensation. Regardless of a Class Member’s decision to accept or decline a third-party claim buyout, each deserves: (1) access to counsel to evaluate third-party claim buyout offers, (2) the opportunity to negotiate for more cash, and (3) protection from potential predatory practices relating to the transaction. Class Members looking for help with these questions to make the best decision can reach out to the Brooklyn Law School Sports Law Clinic using the Client Intake Form.
Written by: Aidan J. Flannery, Brooklyn Law School ‘26, and Samantha H. Lovett, Brooklyn Law School ‘27, both members of the BLS Sports Law Clinic
1 College Athlete Compensation, Coll. Athlete Comp. https://www.collegeathletecompensation.com/ (last visited Feb. 26, 2026). The $2.8 billion reflects the combined settlements in House v. NCAA and Hubbard v. NCAA. Under House, the NCAA and Power Five Conferences agreed to pay $2.57 billion in damages to Class Members barred from monetizing their NIL between 2016-2025 (Damages Class Members). See id. Under Hubbard, the NCAA and Power Five Conferences agreed to pay $200 million to Class Members who competed between 2019-2022. See id.
2 Bernie Dennis, Unpacking the House Settlement’s Impact on Collegiate Athletics, JacksonLewis (Sept. 30, 2025), https://www.jacksonlewis.com/insights/unpacking-house-settlements-impact-collegiate-athletics-0#:~:text=The%20distribution%20framework%20of%20all,5%25%20to%20the%20other%20sports.
3 Dan Murphy, Court Filing Reveals Terms of NCAA Antitrust Lawsuits Settlement, ESPN (Jul. 26, 2024), https://www.espn.com/college-sports/story/_/id/40649389/ncaa-antitrust-lawsuits-settlement-filed-federal-court.
4 Associated Press, 153 NCAA Rules Had to Be Eliminated to Clear the Way for the House Settlement. Numbers to Know, Fox Sports (June 6, 2025), https://www.foxsports.com/articles/wcbk/153-ncaa-rules-had-to-be-eliminated-to-clear-the-way-for-the-house-settlement-numbers-to-know (reporting that 101,935 House Class Members submitted a claim form or updated their payment information entitling them to a damages award).
5 In re: College Athlete NIL Litigation (House) v. NCAA, Sycamore Grove Claims Grp., LLC (last visited Feb. 24, 2026),https://www.sycamoregroveclaims.com/nil-settlement.
6 Sycamore Grove Has Purchased Well Over $100 Million of NIL Settlement Claims from Over 1,000+ NCAA Athletes, Sycamore Grove Claims Grp., LLC https://www.sycamoregroveclaims.com/ (last visited Feb. 26, 2026). Other companies, such as NCAACreditor, offer Class Members a streamlined process to sell their claims, advertising a competitive cash offer within 12 hours of submitting preliminary settlement information and payment within 24 hours of finalizing the transaction. See Convert Your NCAA Settlement Into Immediate Cash, NCAA Creditor https://www.ncaacreditor.com/?utm_source=ig&utm_medium=social&utm_content=link_in_bio&fbclid=PAZXh0bgNhZW0CMTEAc3J0YwZhcHBfaWQMMjU2MjgxMDQwNTU4AAGnKLLtzv4i0MzPlGdTe2GWY1EpAcBd6HmlsyzF8QNs8gPuBioCMsnyg6cEO00_aem_2nt4u6fll1aIT28SP6YuVw (last visited Feb. 26, 2026).
7 Email From Race Johnson, to Aidan J. Flannery, Samantha H. Lovett (Jan. 30, 2026, 3:02 PM EST) (on file with author).
8 Plaintiff’s Renewed Motion for a Prospective Order Concerning Third-Party Claims Buyout Service, In Re College Athlete NIL Litigation, No. 20-cv-03919 at 5 (N.D. Cal. Sept. 5, 2025), ECF No. 1028. https://storage.courtlistener.com/recap/gov.uscourts.cand.360907/gov.uscourts.cand.360907.1028.0.pdf.
9 Order Regarding Third-Party Claims Buyout Services, In Re College Athlete NIL Litigation, No. 20-cv-03919 (N.D. Cal. Sept. 16, 2025), ECF No. 1047 at 2. https://www.collegeathletecompensation.com/media/6203044/ncco_order_regarding_third-party_claims_buyout_services.pdf.
10 Id.
11 Order Regarding Third-Party Claims Buyout Services, In Re College Athlete NIL Litigation, No. 20-cv-03919 (N.D. Cal. Sept. 16, 2025), ECF No. 1047 at 3. https://www.collegeathletecompensation.com/media/6203044/ncco_order_regarding_third-party_claims_buyout_services.pdf.
12 Id.
13 Id.
14 Id.
15 Id.
16 Id.
17 Order Regarding Third-Party Claims Buyout Services, In Re College Athlete NIL Litigation, No. 20-cv-03919 (N.D. Cal. Sept. 16, 2025), ECF No. 1047 at 3-4. https://www.collegeathletecompensation.com/media/6203044/ncco_order_regarding_third-party_claims_buyout_services.pdf. The purchaser of a Class Member’s claim must agree to indemnify Verita Global LLC (the claims administrator), the settlement fund, and the fund’s directors, managers, and employees from losses arising out of the sale of a claim – including disputes over a Class Members’ eligibility for payment, competing claims to the funds, or tax reporting obligations. See id.
18 In re:College Athlete NIL Litigation (House) Frequently Asked Questions, Coll. Athlete Comp. https://www.collegeathletecompensation.com/house-frequently-asked-questions.aspx (last visited Feb. 26, 2026).
19 Third Party Contracts & Settlement Claims for NCAA House Class Members, Hagens Berman Sobol Shapiro LLP (2025), https://www.hbsslaw.com/ncaa-student-athlete-name-image-and-likeness/third-party-contracts-and-settlement-claims-for-ncaa-house-class-members#:~:text=What%20House%20Class%20Members%20Need,down%20before%20they%20are%20finalized.
20 Darren Heitner, Newsletter, Image, Likeness Vol. 143: Cash Now or Hold Out? Navigating Offers to Buy House v. NCAA Settlement Claims, LinkedIn (Aug. 1, 2025), https://www.linkedin.com/pulse/newsletter-image-likeness-vol-143-cash-now-hold-out-offers-heitner-ysule/.
21 See Michael McCann, NCAA Defends House Settlement from Title IX, Opt-Out Appeal, Sportico (Jan. 5, 2026, 11:00 AM), https://www.sportico.com/law/analysis/2026/ncaa-house-settlement-appeal-1234880134/ (indicating that the loser to the Ninth Circuit decision could appeal to the United States Supreme Court, pushing “the litigation clock back another year or two”).
22 See Darren Heitner, Newsletter, Image, Likeness Vol. 143: Cash Now or Hold Out? Navigating Offers to Buy House v. NCAA Settlement Claims, LinkedIn (Aug. 1, 2025), https://www.linkedin.com/pulse/newsletter-image-likeness-vol-143-cash-now-hold-out-offers-heitner-ysule/ (arguing that “if appeals succeed, some athletes could end up with nothing”); see Michael McCann, NCAA Defends House Settlement from Title IX, Opt-Out Appeal, Sportico (Jan. 5, 2026, 11:00 AM), https://www.sportico.com/law/analysis/2026/ncaa-house-settlement-appeal-1234880134/ (articulating that there is a good chance that the 9th Circuit will be deferential to Judge Wilkens’ decision); see Shehan Jeyarajah & Brandon Marcello, House v. NCAA Settlement Payments on Hold Amid Legal Challenge from Female Athletes on Title IX Grounds, CBS Sports (June 11, 2025, 2:28 PM), https://www.cbssports.com/college-football/news/house-v-ncaa-settlement-payments-on-hold-amid-legal-challenge-from-female-athletes-on-title-ix-grounds/.
23 See id. In some cases, third-party claim buyer offers can be as low as 10%-20% of the total settlement payout. Id.
24 In re: College Athlete NIL Litigation (House) Frequently Asked Questions, Coll. Athlete Comp. https://www.collegeathletecompensation.com/house-frequently-asked-questions.aspx (last visited Feb. 23, 2026); see also Darren Heitner, Newsletter, Image, Likeness Vol. 143: Cash Now or Hold Out? Navigating Offers to Buy House v. NCAA Settlement Claims, LinkedIn (Aug. 1, 2025), (providing evidence that while “[t]here’s usually a short “cooling off” period—say, 10 days—to back out, but after that, it’s binding…[complicating] an athlete’s ability to reclaim control if regrets set in”).
25 In re: College Athlete NIL Litigation (House) Frequently Asked Questions, Coll. Athlete Comp. https://www.collegeathletecompensation.com/house-frequently-asked-questions.aspx (last visited Feb. 23, 2026).
26 Id.
27 Id.
28 Id. Specifically, the website advises that while “Class Members have the right to sell their claims if they choose to do so…[they] may be forfeiting any and all rights to receive additional income or future payments under the settlement agreement.” Id.
29 Catherine Cote, Time Value of Money (TVM): A Primer, Harv. Bus. Sch. Online (June 16, 2022), https://online.hbs.edu/blog/post/time-value-of-money (outlining that “TVM calculations ‘translate’ all future cash to its present value”).
30 See id. The present value formula is PV=FV/(1+i)n where FV = amount of money expected to be paid in the future, i = the interest rate, and n = number of years over which FV will be paid. Id.
31 Id.