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Originally Posted by Resolute 14
I have no idea on what grounds the NHLPA could sue and have any hope of winning, but the rest of your post is accurate.
I'm going to guess you're going to argue the union would sue over lost revenue under the theory that Calgary generates more revenue than any relocation market could achieve. Except (1) that's completely unprovable and (2) the CBA doesn't place any such limits.
Historically, the people with the best success suing over a threatened relocation has been the cities themselves. Major League Baseball especially has had to place numerous teams in markets due to lawsuits, injunctions and threats. Including Toronto, who very nearly ended up being awarded teams in both the AL and NL simultaneously.
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NHLPA case would be based on the fact that the Board was making decisions to deliberately reduce HRR without consulting or getting the approval of the PA.