Knicks and Raptors: How Two Federal Acts are Intertwined with the NBA

By Mikayla Watts ‘26

Introduction

Two teams in the National Basketball Association (NBA) have found themselves in competition, but this time, it involves a different type of court. The New York Knicks, LLC, have brought a lawsuit against six defendants, all associated with the Toronto Raptors in some capacity. The owner of the Raptors, Maple Leaf Sports & Entertainment Ltd. (MLSE), is the first defendant named in the complaint. This is followed by Raptors’ head coach, Darko Rajaković, player development coach, Noah Lewis, and an additional ten unknown employees, each named “John Doe.” A final defendant named in the complaint is Ikechukwu Azotam, a former employee of the New York Knicks, and a current employee of the Toronto Raptors.

Azotam was the Director of Video/Analytics/Player Development Assistant for the New York Knicks. In working with the Knicks organization, Azotam had access to much confidential information regarding the Knicks themselves, as well as other teams in the NBA. Much of this information includes “scouting reports, play frequency reports, a prep book, and a link to third-party licensed software,” which allegedly was illegally given to the Raptors organization, according to the complaint. Azotam was hired by the Raptors in 2023, with the Knicks arguing that the months leading up to this new role were filled with conspiracy between Azotam and the Raptors, as well as explicit illegal trading of proprietary information. 

The Knicks allege harm by the defendants on eight different counts: violation of the Computer Fraud and Abuse Act, violation of the Defend Trade Secrets Act, misappropriation of trade secrets under New York common law, breach of contract, tortious interference with contractual relations, conversion, unfair competition, and unjust enrichment.

Computer Fraud and Abuse Act

Delving deeper into the two federal acts mentioned, they claim a violation of the Computer Fraud and Abuse Act 18 U.S.C. § 1030 (CFAA). The Knicks specifically mention 1030(a)(2)(C), 1030(e)(2)(B), and 1030(b). According to Cornell Law School, the first subsection prohibits accessing a computer “without authorization or exceeding authorized access,” and gaining information. 1030(e)(2)(B) prohibits any action of unlawfully accessing a computer that is “used in or affecting interstate commerce or foreign commerce or communication,” being used in a way that influences such commerce or communication. 1030(b) directly prohibits the act of anyone who “conspires to commit…offense under subsection (a).” 

This alleged violation focuses on a computer service called Synergy Services used by the Knicks. According to the complaint, the service deals with “archiving digital video content and related metadata of basketball games, including proprietary play-type statistics.” This is a service paid for by the Knicks organization, from which they claim Azotam took confidential information and gave it to the Raptors. 

The violation of the first subsection comes into play when the Knicks allege that the Raptors gained access to the Synergy videos, seeing as they claim nobody outside of the organization had rightful access to the service. The plaintiff expressly alleges that 1030(b) was violated, as they claim that the sharing of the confidential information from Synergy Services was planned between the Raptors and Azotam, leading up to his new Raptors position. Furthermore, the criteria laid out in 1030(e)(2)(B) is easily met if the violation in the first subsection is proven. Synergy is used by an organization that operates across state lines, and even into Canada, meeting the “interstate or foreign commerce” requirement. Again, if 1030(a)(2)(C) is proven, then the gathering of this information by the Raptors would most likely affect the foreign commerce. The performance of both teams is likely to shift if this information were gathered by one organization unlawfully. At its most technical level, the NBA is a business, meaning that if the performance of either organization changes, so does its revenue, sponsorships, television deals, etc. 

Defend Trade Secrets Act

The second act that is specifically stated is the Defend Trade Secrets Act 18 U.S.C § 1832 (DTSA), which the plaintiff contends has been violated by the defendants. The statute, according to Cornell Law School, states that anyone who intends to use “ a trade secret, that is related to…interstate or foreign commerce, to the economic benefit of anyone other than the owner, and…knowing that the offense will, injure any owner of that trade secret.” 18 U.S.C § 1839 defines the term trade secret to include “all forms and types of financial, business,” or economic “information.” Section 1839 requires that the information “derives independent economic value…from not being readily ascertainable through proper means.” The section also requires that the owner of the trade secret(s) take precautionary measures to keep the information confidential, which the Knicks contend they do, as they lay out the multiple security measures they take to do so. 

This Act is where the previously mentioned scouting and frequency reports and the prep book come into play from the complaint. While this information is common among NBA organizations, it is almost never shared between teams. This specifically is important when analyzing the statute’s language that reads “knowing that the offense will, injure any owner of that trade secret,” as well as the requirement of the information “not being readily ascertainable.” In proving this violation, it will be of importance to point out the fact that it is more than likely that staff in the Raptors organization understands the confidential nature of this type of information. This information is gathered independently and subsequently used to improve the organization’s work, both on and off the court. If proven to be the case that this information was in fact obtained by the Raptors organization unlawfully, then a violation of section 1832 would have occurred. 

Once again, things such as scouting and play frequency reports fall under the definition of trade secrets, as they can substantially affect a team’s processes or methods. A shift in how an organization runs can cause a change in its financial standing, as once again, it can affect performance, and subsequent economic benefits. 

Relief

The first solution that the Knicks are looking for from the court is an injunction against the defendants. Specifically, they are seeking an injunction from the court to order the defendants to stop sharing, as well as receiving confidential information from the Knicks organization. Furthermore, the complaint states that the plaintiff is seeking a judgement that the defendants’ actions were “willful and malicious,” as well as find that Azotam should receive no benefit of any kind from the alleged “misappropriation and wrongful acts.”

The final form of relief that the Knicks are seeking is in the form of monetary damages. They are seeking both compensatory and exemplary (punitive) damages. These damages, according to the complaint, are to compensate for costs, such as attorney’s fees. Furthermore, the Knicks are seeking disgorgement damages in response to the alleged unjust enrichment. According to Cornell Law School, these types of damages entail the order to “give up any profits…made as a result of that illegal or wrongful conduct.” The total amount of damages the plaintiff is seeking adds up to $10 million total.

Interestingly, United States District Judge Jessica Clarke has ordered that this proceeding be settled outside of a courtroom. According to the opinion, the NBA Constitution contains an arbitration clause where the commissioner has “exclusive jurisdiction over any dispute involving two NBA teams.” Chicago Law School graduate and NBA Commissioner, Adam Silver, will be tasked with arbitrating this issue between these two teams in mid-July of 2025. 

Mikayla Watts is a junior majoring in criminal justice and philosophy.

Sources

disgorgement. (n.d). Cornell Law School. Retrieved April 16, 2025 from https://www.law.cornell.edu/wex/disgorgement 

New York Knicks, LLC v. Maple Leaf Sports & Entertainment LTD. d/b/a Toronto Raptors, Complaint. (2023, August 21). Court Listener. Retrieved April 10, 2025 from https://www.courtlistener.com/docket/67710719/1/new-york-knicks-llc-v-maple-leaf-sports-entertainment-ltd-dba/ 

New York Knicks, LLC v. Maple Leaf Sports & Entertainment LTD. d/b/a Toronto Raptors, Memorandum of Law in Opposition to Motion. (2023, November 21). Court Listener. Retrieved April 11, 2025 from https://www.courtlistener.com/docket/67710719/35/new-york-knicks-llc-v-maple-leaf-sports-entertainment-ltd-dba/ 

New York Knicks, LLC v. Maple Leaf Sports & Entertainment LTD. d/b/a Toronto Raptors, Memorandum & Opinion AND ~Util - Case Stayed. (2024, June 28). Court Listener. Retrieved April 22, 2025 from https://www.courtlistener.com/docket/67710719/46/new-york-knicks-llc-v-maple-leaf-sports-entertainment-ltd-dba/

Norton, A. (2023, January 6). New York Knicks vs Toronto Raptors Preview (1/6/23): Prediction, Starting Lineups, Odds. Lineups. Retrieved April 22, 2025 from https://www.lineups.com/articles/new-york-knicks-vs-toronto-raptors-preview-1-6-23-prediction-starting-lineups-odds/ 

Taranto, S. (2025, March 2). Long-running legal dispute between Raptors, Knicks to be settled in July as New York seeks $10M in damages. CBS Sports. Retrieved April 22, 2025 from https://www.cbssports.com/nba/news/long-running-legal-dispute-between-raptors-knicks-to-be-settled-in-july-as-new-york-seeks-10m-in-damages/ 

18 U.S. Code § 1030 - Fraud and related activity in connection with computers. (n.d). Cornell Law School. Retrieved April 14, 2025 from https://www.law.cornell.edu/uscode/text/18/1030 

18 U.S. Code § 1832 - Theft of trade secrets. (n.d.). Cornell Law School. Retrieved April 14, 2025 from https://www.law.cornell.edu/uscode/text/18/1832 

18 U.S. Code § 1839 - Definitions. (n.d.). Cornell Law School. Retrieved April 22, 2025 from, https://www.law.cornell.edu/uscode/text/18/1839