FIFA Likely to Permit Matches Played Outside a League’s Home Territory in Aftermath of Relevent Settlement

In the 120+ years since the founding of the Fédération Internationale de Football Association (FIFA), association football (soccer) became the world’s game. From its humble European beginnings, FIFA now comprises 211 member countries and territories across six continents.¹[1]Member Associations, FIFA, https://inside.fifa.com/associations. Unsurprising, then, is the colossal global audience for the premier club and international soccer competitions.²[2]Ira Boudway, Soccer is the World’s Most Popular Sport and Sill Growing, Bloomberg (June 12, 2018), https://www.bloomberg.com/news/articles/2018-06-12/soccer-is-the-world-s-most-popular-sport-and-still-growing?embedded-checkout=true. This article addresses the challenges and opportunities for international soccer in bringing their games to an American audience, especially in the aftermath of the settlement in Relevent Sports, LLC v. United States Soccer Federation, Inc.³[3]Compl, Relevent Sports, LLC v. Fédération Internationale De Football Ass’n., 19- CV-8359, 2021 U.S. Dist. LEXIS 135017, at *7-8 (S.D.N.Y. July 20, 2021).

Bringing European Soccer to American Audiences

As a result of the globalization of soccer, many leagues and teams have sought media rights deals outside their home markets. The top European soccer leagues are now targeting the United States for their game broadcasts. Spain’s La Liga has entered a media rights deal with ESPN+ to broadcast its games in the U.S., with its President Javier Tebas observing it is the “largest media market in the world.”⁴[4]ESPN+ new home of Barcelona, Real Madrid with multi-year La Liga deal, ESPN (May 13, 2021), https://www.espn.com/soccer/story/_/id/37617179/espn+-new-home-barcelona-real-madrid-multi-year-la-liga-deal. The Bundesliga – Germany’s top flight –similarly agreed to a six-year media rights deal with ESPN+ in 2019 to broadcast matches to the American audience.⁵[5]Manuel Veth, ESPN and Bundesliga Sign Six-Year U.S. Television Deal, Forbes (Sept. 30, 2019), https://www.forbes.com/sites/manuelveth/2019/09/30/espn-and-bundesliga-sign-six-year-us-television-deal/. Other top domestic and continental competitions such as Italy’s Serie A and the Union of European Football Association’s (UEFA) continental cup competitions followed suit by agreeing to deals with Paramount+/CBS Sports.⁶[6]Chuck Booth, UEFA and CBS Sports/Paramount+ reach six-year deal to are Champions League, Europa, and Conference League, CBS Sports (Aug. 19, 2022), https://www.cbssports.com/soccer/news/uefa-and-cbs-sportsparamount-reach-six-year-deal-to-air-champions-league-europa-and-conference-league/; Emmet Gates, Serie A Continue North American TV Deal With Paramount/CBS Sports, Forbes (June 20, 2024), https://www.forbes.com/sites/emmetgates/2024/07/20/serie-a-continue-north-america-tv-deal-with-paramountcbs-sports/. The latest agreement between NBC and the English Premier League, arguably the top domestic league in the world, represents more than five times the value of the parties’ first agreement signed in 2013, similarly reflecting soccer’s current expansion in the American market.⁷[7]Adam Crafton, NBC to continue push for Premier League games in the U.S., says leading exec, The Athletic (April 30, 2024), https://www.nytimes.com/athletic/5460003/2024/04/30/premier-league-games-united-states-nbc/.

In addition to media rights deals, an alternative route for soccer’s invasion of the American sports market is playing matches between European clubs on American soil. Americans are familiar with the concept of top U.S. leagues playing official season contests abroad. The National Football League launched its International Series in 2007 by staging a regular-season match between the New York Giants and Miami Dolphins at London’s Wembley Stadium.⁸[8]The NFL International Series, NFL Operations, https://operations.nfl.com/journey-to-the-nfl/the-nfl-s-international-impact/the-nfl-international-series/#:~:text=The%20NFL%20launched%20the%20International,season%20NFL%20game%20each%20season. It plans to play seven regular-season games outside the U.S. in 2025. Major League Baseball, the National Basketball Association, and the National Hockey League also have histories of playing regular-season competitive matches in multiple countries.⁹[9]David Adler, MLB’s history of games played abroad, MLB.com (March 19, 2025), https://www.mlb.com/news/baseball-games-played-outside-the-us-c272441130; Penguins Predators to play 2025 NHL Global Series in Sweden, NHL.com (Mar. 18, 2025), https://www.nhl.com/news/topic/nhl-global-series/penguins-predators-to-play-2025-nhl-global-series-in-sweden.

However, replicating that process for official season matches is more arduous for the top European soccer leagues for at least two reasons. First, European fans are not so keen on moving their favorite club’s home matches abroad. For example, when Liverpool FC owner Tom Werner hinted to the Financial Times that he is determined to have an English Premier League match in New York City,¹⁰[10]Sara Germano, How Liverpool and Red Sox owner John Henry won it all, Financial Times (June 7, 2024), https://www.ft.com/content/919b2e46-0c2d-4eca-ac7f-0507d86dc0b5. the chair of the Liverpool FC Supporters Board met with the club to ensure Werner’s idea “would only be put forward if it was right for everyone, including and most importantly, supporters.”¹¹[11]Liverpool FC Supporters Board (@_lfcsb), “On behalf of the Supporters Board, our chair has spoken directly to the Club. They have told us that Tom Werner’s comment was a personal idea, not LFC’s, which would only be put forward for consideration if it was right for everyone, including and most importantly, supporters.”, (June 7, 2024, 3:14 PM), Tweet, https://x.com/_lfcsb/status/1799157979973034143.

Second, FIFA rules may pose an even greater hurdle for leagues seeking to play official season matches abroad. In 2018, FIFA’s ruling council announced a policy that official season matches must be played within the territory of the respective member association.¹²[12]Jeff Carlislie, Explaining the Relevent lawsuit v.s. U.S. Soccer, FIFA, ESPN (July 30, 2024), https://www.espn.com/soccer/story/_/id/40645598/relevent-fifa-us-soccer-lawsuit-explained. That meant that La Liga, for example, must locate all official season matches between Real Madrid and Barcelona in Spain. FIFA eventually incorporated this policy into its official statutes on “International Matches and Competitions,” which state: “Member associations and their clubs may not play on the territory of another member association without the latter’s approval.”¹³[13]FIFA Statutes and Regulations art. 71 (2022). The rules further require the consent of all member associations and the destination confederation involved when two clubs play a match outside their home territories.¹⁴[14]Id. So, while preseason and exhibition European soccer matches have long been played in the United States, FIFA rules barred staging an official season match on American soil.

Relevent Sports Challenges the Territorial Policy

FIFA’s territorial policy precipitated the antitrust claims in Relevent Sports, LLC v. United States Soccer Federation Inc., alleging that FIFA and its member associations were illegally dividing geographic markets.¹⁵[15]Relevent Sports, LLC v. U.S. Soccer Fed’n Inc., 21-2088-cv, 2023 U.S. App. LEXIS 5385, at *3 (2nd Cir. Mar. 7, 2023). With the recent settlement of that case, FIFA’s policy will likely change in the near future, triggering an influx of competitive European soccer matches in the United States.

Leading up to the lawsuit, Relevent Sports, a promoter of international soccer matches, for many years organized exhibition preseason matches and tournaments in the United States between giants of European soccer.¹⁶[16]Kevin Draper, Relevent Sports Sues U.S. Soccer, Escalating Fight Over Sanctioning, N.Y. Times (Apr. 22, 2019), https://www.nytimes.com/2019/04/22/sports/relevent-sports-us-soccer-lawsuit.html. In 2018, Relevent, in a joint venture with La Liga, attempted to organize an official league match between FC Barcelona and Girona FC in Miami.¹⁷[17]Jeff Carlislie, Explaining the Relevent lawsuit v.s. U.S. Soccer, FIFA, ESPN (July 30, 2024), https://www.espn.com/soccer/story/_/id/40645598/relevent-fifa-us-soccer-lawsuit-explained. Relevent and La Liga, in compliance with the FIFA rule, sought approval to stage the match from the necessary member associations and confederation, including the United States Soccer Federation (USSF), the Real Federación Española de Fútbol (RFEF); and the Confederation of North, Central America, and Caribbean Association Football (CONCACAF). Those three entities jointly requested guidance from the FIFA Council on the issue.¹⁸[18]FIFA Council makes key decisions for the future of football development, FIFA (Oct. 26, 2018), https://www.fifa.com/tournaments/mens/futsalworldcup/lithuania2021/media-releases/fifa-council-makes-key-decisions-for-the-future-of-footballdevelopment.

After consulting the FIFA Stakeholder Committee, the FIFA Council “emphasized the sporting principle that official league matches must be played within the territory of the respective member association.”¹⁹[19]Id. Subsequent opposition from the Spanish Footballers Association²⁰[20]Jeff Carlislie, Explaining the Relevent lawsuit v.s. U.S. Soccer, FIFA, ESPN (July 30, 2024), https://www.espn.com/soccer/story/_/id/40645598/relevent-fifa-us-soccer-lawsuit-explained. and other parties led to Barcelona withdrawing from the plan “until there is an agreement between all parties.”²¹[21]Barça withdraw disposal to play in Miami, FCBarcelona.com (Dec. 11, 2018). https://www.fcbarcelona.com/en/club/news/940120/barca-withdraw-disposal-to-play-in-miami?utm_source=twitter&utm_medium=fcbarcelona&utm_campaign=ff371287-c2b6-494a-9e4f-50a5d69cc326. In Spring 2019, Relevent attempted to host another official league match in Miami between Guayaquil City FC and Barcelona SC, clubs in LigaPro, Ecuador’s top flight.²²[22]Relevent Sports, LLC, 21-2088-cv, 2023 U.S. App. LEXIS 5385, at *6. Pursuant to FIFA’s policy, the USSF denied that request.²³[23]Id.

In September 2019, Relevent brought its antitrust suit against the USSF²⁴[24]Compl, at 1, Relevent Sports, LLC v. Fédération Internationale De Football Ass’n., 19- CV-8359, 2021 U.S. Dist. LEXIS 135017, at *7-8 (S.D.N.Y. July 20, 2021). and later added FIFA as a defendant.²⁵[25]Relevent Sports, LLC v. Fédération Internationale De Football Ass’n., No. 1:19-cv-08359, S.D.N.Y., Req. for Issuance of Summons as to FIFA (filed Sept. 14, 2020). Relevent claimed that FIFA and its member associations engaged in an unlawful vertical agreement to divide the market among leagues and teams, and the leagues and teams were in an unlawful horizontal agreement to adhere to the policy.²⁶[26]Relevent Sports, LLC v. Fédération Internationale De Football Ass’n., 19- CV-8359, 2021 U.S. Dist. LEXIS 135017, at *7-8 (S.D.N.Y. July 20, 2021). USSF argued that it wasn’t conspiring with FIFA, but was simply following FIFA’s rules in refusing to allow a foreign league match. The New York federal court agreed and dismissed the lawsuit, holding that USSF’s compliance with the rule, “without additional factual allegations, is insufficient to constitute direct evidence of an unlawful agreement.”²⁷[27]Id. at *13. On appeal, the Second Circuit reinstated the complaint, holding that the promulgation of the FIFA rule constitutes sufficient evidence of an agreement.²⁸[28]Id.; 15 U.S.C. § 1. The parties then proceeded with discovery and preparation for trial.

In April 2024, Relevent settled with and dismissed FIFA without prejudice. . Under the settlement, FIFA agreed to comply with any court injunction against the rule on matches played outside a league’s home country.²⁹[30]Id. ¶ 4. A year later, Relevent settled with the USSF and, as of April 2025, the lawsuit has been dismissed with prejudice.³⁰[31]Notice of Voluntary Dismissal of Defendant USSF, Inc. (filed April 9, 2025). While the parties have not disclosed the details of the settlement, it is expected to clear the way for European league games in the U.S.³¹[32]Jeff Carlisle, USSF, Relevent settlement clears path for foreign league games, ESPN (April 10, 2025), https://www.espn.com/soccer/story/_/id/44610691/ussf-relevent-settlement-clears-path-foreign-league-games.

Antitrust Limits on Sports Governing Bodies’ Ability to Restrict Market Access

Relevent Sports was not the first time a U.S. court held that a sports governing body’s rules constitute an agreement sufficient for application of Section 1 of the Sherman Act. In 2019, a California federal court denied a motion to dismiss the complaint in International Swimming League v. Fédération Internationale De Natation (“FINA”).³²[33]Order Re: Defendant’s Motions to Dismiss Following Supplemental Briefing on Personal Jurisdiction, Thomas A. Shields et al., v. Fédération Internationale de Natation International Swimming League, Ltd. v. Fédération Internationale de Natation, Cases No. 18-cv-07393-JSC, No. 18-cv-07394-JSC (N.D. Cal. 2019). A start-up professional swimming league had sued FINA (now known as World Aquatics), alleging that the swimming federation used its control over the sport to bar athletes from swimming in competitions outside the Olympic Games and FINA’s own events. The court rejected FINA’s single entity defense because its member federations are potential competitors capable of antitrust conspiracy.³³[34]Id. at 36; Id. This decision aligns with the Second Circuit’s ruling in Relevent Sports that a national sports governing body cannot escape antitrust liability by claiming it does not conspire with its international sports governing body and member federations.

Similarly, European courts agree that sports governing bodies cannot deny event promoters market access. In International Skating Union v. Commission, the General Court of the European Union found that a pre-authorization system, like that in the FIFA rule, requires a longer and more complicated process for third party applicants than for members.³⁴[35]Case T-93/18, Int’l Skating Union v. Eur. Comm’n., 2020 ECLI:EU:T:2020:610 ¶ 110 (Dec. 16, 2020). This requirement also grants the sports governing body broad discretionary authority to reject the request or not make a timely decision on the request.³⁵[36]Id. The European court acknowledged this was evidence of an anticompetitive process barring competition, not a procompetitive one of ensuring an applicant meets certain minimum standards.³⁶[37]Int’l Skating Union v. Eur. Comm’n., 2020 ECLI:EU:T:2020:610 ¶ 110. This observation similarly dovetails with the Second Circuit holding in Relevent Sports that plaintiffs provided sufficient evidence of an agreement between USSF and FIFA.³⁷[38]Relevent Sports, LLC, 21-2088-cv, 2023 U.S. App. LEXIS 5385, at *23. Here, the International Skating Union’s process favored its own competitions and thereby failed to “ensure effective access” to market for skating competitions.³⁸[39]Id. ¶ 119.

One decision on the country level in Europe seems to align with the General Court of the European Union. In Svenska Bilsportförbundet v. Konkurrensverket, Swedish courts rejected the solidarity clauses that restricted race participants to the established motorsports federation. . In its opinion, the court noted SBF used the clause to deprive other industry actors of their right to compete in the market. . Both European and Swedish courts recognized that a sports governing body restrictions on market access for others are anticompetitive.

Conclusion

Ultimately, the weight of the jurisprudence and the likely terms of the Relevent settlement agreement will compel FIFA to open up market access to extraterritorial matches. In Europe and the United States, courts view geographic market restrictions like FIFA’s as evidence of an antitrust conspiracy at best and plainly anticompetitive at worst. Accordingly, FIFA announced it will form a group to recommend changes to its current rule governing matches played on foreign soil.³⁹[42]FIFA Council appoints working group to recommend potential rule changes to the Current FIFA Regulations Govering International Matches, InsideFIFA (May 15, 2024), https://inside.fifa.com/organisation/fifa-council/news/fifa-council-appoints-working-group-to-recommend-potential-rule-changes. Further, UEFA has granted Relevent exclusive negotiating rights “over the global commercial rights to the UEFA men’s club competitions for the period 2027-2033.”⁴⁰[43]Graham Dunbar, Champions League global rights deal set to be struck by U.S. agency Relevent, clubs, AP News (Feb. 11, 2025), https://apnews.com/article/uefa-champions-league-marketing-rights-relevent-9caf9117ee22684c20dba33f3c273a00. Additionally, Relevent and the Deutsche Fußball Liga, the governing body of the Bundesliga, agreed to a new long-term partnership in September 2024.⁴¹[44]Manuel Veth, Bundesliga Enters Partnership With Relevent To Help Expansion On Important US Market, Forbes (Sept. 19, 2024), https://www.forbes.com/sites/manuelveth/2024/09/19/bundesliga-enters-partnership-with-relevant-to-help-expansion-on-important-us-market/. Expect top European teams playing competitive matches in the United States in the near future.

By: Ben Lesserson, J.D. Candidate, 2026