Did they address the venue issue at all in the filing?
They tie facts in this case to the Adrian Petersen case
On July 28, 2015, Commissioner Goodell issued the Award upholding
Brady's discipline in its entirety. The Award is self-effectuating.
96. Despite this fact, the NFL engaged in attempted preemptive forum
shopping by filing-virtually simultaneously with the issuance of the Award (the timing
of which was unknown to the Union and Brady)-a proceeding to confirm the award in
the Southern District of New York. The League knew that the central notice issues the
CASE 0:15-cv-03168-RHK-HB Document 1 Filed 07/29/15 Page 32 of 54
Union had raised in the arbitration were directly related to the Peterson proceedings
pending before this Court and yet deliberately sought to avoid review by this Court.
97. The next day, the NFLPA and Brady filed this Petition and will shortly
hereafter file a Motion for Preliminary Injunction, or in the Altemative, for Expedited
Disposition, seeking to have Brady's suspension enjoined prior to September 4,201'5 in
order to prevent him from suffering severe and irreparable harm from the loss of regular
season games due to his unlawful suspension.
also
JURISDICTION AND VENUE
29. This is an action to vacate the Award pursuant to Section 301 of the LMRA
and Section l0 of the FAA. This Court has subject matter jurisdiction in this action
pursuant to 28 U.S.C. $ 1331.
30. The NFL derives revenue from advertising, ticket sales, merchandising and
broadcast revenue throughout the State of Minnesota and is subject to personal
jurisdiction here. The Minnesota Vikings, one of 32 NFL franchises, is headquartered in
Eden Prairie, Minnesota and does business in this district.
31. Venue is proper in this court under 28 U.S.C. $ 1391 and 29 U.S.C. $ 185,
as the NFL regularly transacts business in this district.