Chalmers v. NCAA: Strict Time Limits on Retroactive NIL Antitrust Claims in the Second Circuit

1. Introduction

In Chalmers v. National Collegiate Athletic Association, No. 25‑1307‑cv (2d Cir. Dec. 15, 2025) (summary order), the United States Court of Appeals for the Second Circuit affirmed the dismissal of a putative class action brought by former Division I men’s basketball players against the NCAA and six major athletic conferences. The plaintiffs alleged a long-running antitrust conspiracy and related unjust enrichment arising from the uncompensated commercial exploitation of their names, images, and likenesses (NIL) in NCAA-related media and licensing deals.

Although the opinion is a “summary order” and thus non‑precedential under Second Circuit rules, it is nonetheless citable and provides a clear, structured application of several critical doctrines:

• Accrual and limitation of antitrust claims under the Sherman and Clayton Acts;
• The limits of the continuing violation doctrine when an initial rights-transfer drives later exploitation;
• The narrow “speculative damages” exception to the antitrust accrual rule;
• Equitable tolling of antitrust claims in the shadow of widely publicized prior litigation;
• Application of laches to bar equitable (injunctive) relief where legal claims would be time‑barred; and
• The treatment of unjust enrichment as duplicative of federal antitrust claims under New York law.

In the rapidly evolving NIL landscape following NCAA v. Alston, 594 U.S. 69 (2021), Chalmers sends an important message: former athletes seeking retroactive NIL compensation for conduct rooted in pre‑2016 NCAA rules face formidable timing and equitable barriers in the Second Circuit.

2. Factual and Procedural Background

2.1 The Parties and the Putative Class

The sixteen named plaintiffs are former men’s Division I basketball players whose collegiate careers spanned from 1994 to 2015. They sued:

• The NCAA; and
• Six major conferences: the Big East, Pac‑12, Big Ten, Big 12, Southeastern Conference (SEC), and Atlantic Coast Conference (ACC).

The putative class consisted of:

“[A]ll individual persons who were NCAA student-athletes prior to June 15, 2016, whose image, likeness, or footage has been used or licensed for commercial purposes by the NCAA, the Conferences, or their affiliates.”

The focus on “prior to June 15, 2016” reflects the last possible date any class member would have been required to sign the NCAA’s Student‑Athlete Statement containing a NIL authorization.

2.2 The NCAA’s NIL Framework and the Alleged Conspiracy

According to the complaint, by no later than the 1980s the NCAA and its conference members:

• Entered into an agreement to suppress competition in “the supply market for images and footage of student-athletes’ past athletic performances”;
• Agreed not to compensate student-athletes for the creation or commercial use of images/footage depicting their performances;
• Agreed not to recognize any student-athlete ownership claims in such images/footage; and
• Agreed to “usurp all ownership rights” and to use those images/footage for their own commercial benefit.

To implement this, the NCAA required student-athletes, each academic year, to sign a Student-Athlete Statement as a condition of eligibility under NCAA Bylaw 14.1.3.1. One typical clause stated:

“You authorize the NCAA [or a third party acting on behalf of the NCAA] to use your name or picture to generally promote NCAA championships or other NCAA events, activities or programs.”

The NCAA allegedly interpreted this “seemingly simple statement” as granting a perpetual license to use the athlete’s NIL in connection with footage created during their collegiate career. Plaintiffs labeled this assignment:

• Product of coercion;
• An “instrument of illegal conduct”; and
• Contrary to public policy, and thus void.

The NCAA and conferences, in turn, entered into lucrative media rights agreements that allegedly included value for historical footage featuring the plaintiffs and putative class members, without any NIL compensation flowing to the athletes.

2.3 Claims Asserted

On these facts, the plaintiffs asserted:

1. Sherman Act § 1 – unreasonable restraint of trade;
2. Sherman Act § 1 – unreasonable restraint via group boycott/refusal to deal;
3. Sherman Act § 2 – monopolization of the relevant NIL supply market; and
4. Unjust enrichment under state common law (applied as New York law by the district court).

They sought both damages (including treble damages under the Clayton Act) and equitable relief, including injunctive remedies and, effectively, a constructive trust over NIL‑related revenues.

2.4 District Court Disposition

Judge Engelmayer of the Southern District of New York dismissed the amended complaint with prejudice under Rule 12(b)(6), holding:

1. All Sherman Act damages claims were barred by the four-year statute of limitations in 15 U.S.C. § 15b, and were not saved by any accrual exception or equitable tolling.
2. Claims for injunctive relief were barred by laches.
3. Doctrines of preclusion (claim/issue preclusion and settlement releases) independently barred much of the case, due to prior NIL/compensation class actions in the Northern District of California, namely:
   • O’Bannon v. NCAA, 7 F. Supp. 3d 955 (N.D. Cal. 2014), aff’d in part & vacated in part, 802 F.3d 1049 (9th Cir. 2015); and
   • The settlement in In re: NCAA Athletic Grant-in-Aid Cap Antitrust Litigation (“Alston”), No. 4:14‑md‑02541 (N.D. Cal. Dec. 6, 2017).
4. Unjust enrichment was:
   • Duplicative of the antitrust claims;
   • Untimely; and
   • For ten plaintiffs, separately barred by the Alston settlement and claim preclusion.

The plaintiffs appealed, challenging each of these rulings. The Second Circuit affirmed in full, focusing primarily on timeliness and duplicativeness, and leaving most preclusion questions in the background.

3. Summary of the Second Circuit’s Holding

The Second Circuit (Judges Calabresi, Lynch, and Merriam) affirmed the dismissal on four principal grounds:

1. Statute of limitations for Sherman Act damages claims:
   • Antitrust causes of action generally accrue upon injury.
   • Here, the injury was the coerced transfer and loss of NIL rights when the athletes signed the Student-Athlete Statements during their collegiate careers.
   • The last possible signing date was June 14, 2016; the suit was filed July 1, 2024—more than four years later.
   • The continuing violation doctrine does not apply because later commercial uses of NIL are merely manifestations of the initial rights transfer, not independent, new overt acts.
   • The “speculative damages” exception does not apply; plaintiffs’ injury—exclusion from the market for their own NIL—was calculable when they signed the Statements.
   • Equitable tolling is unavailable because plaintiffs did not show extraordinary circumstances or diligent pursuit, especially in light of prior high-profile NCAA antitrust lawsuits.
2. Laches bars injunctive relief:
   • The analogous statute of limitations for antitrust damages (four years under the Clayton Act) had long expired.
   • Plaintiffs’ delay—over a decade for many—was unreasonable and prejudicial, particularly when others had brought similar suits much earlier.
   • Plaintiffs’ arguments about NCAA “environment” and pre‑Alston “practical legal impediments” were rejected.
3. Unjust enrichment is duplicative:
   • Under New York law, unjust enrichment is not a catch‑all; it fills gaps where no other legal duty or tort applies.
   • Here, unjust enrichment rested on the same core facts and sought the same economic recovery as the federal antitrust claims.
   • Because it was duplicative of those statutory claims, the unjust enrichment count was properly dismissed.
4. Other arguments rejected:
   • The panel rejected plaintiffs’ remaining arguments as meritless and affirmed the district court’s judgment.

The court applied de novo review and accepted all well-pleaded allegations as true, but held that the claims were barred “as a matter of law” on the face of the complaint and matters subject to judicial notice.

4. Detailed Analysis

4.1 Antitrust Statute of Limitations and Accrual

4.1.1 General Accrual Rule

The core statutory provision is 15 U.S.C. § 15b:

“Any action to enforce any cause of action under [15 U.S.C. §§ 15, 15a, 15c] shall be forever barred unless commenced within four years after the cause of action accrued.”

Under cases like Higgins v. New York Stock Exchange, 942 F.2d 829 (2d Cir. 1991), and Zenith Radio Corp. v. Hazeltine Research, Inc., 401 U.S. 321 (1971), an antitrust cause of action generally accrues “as soon as there is an injury to competition,” i.e., when the plaintiff suffers injury in its business or property.

Here, the appellate court held that injury occurred, at the latest, when each plaintiff signed the Student-Athlete Statement—because:

• The signature was the moment at which the NCAA allegedly “stripped them of their legal rights” to exploit their NIL; and
• They were thereby excluded from the “market for the supply of images and footage of” their own athletic performances.

Even though much of the financial impact would be realized later, that does not postpone accrual.

4.1.2 Rejection of the Continuing Violation Doctrine

Plaintiffs argued that each subsequent use of their NIL (e.g., in new broadcasts, licensing deals, advertising) was a fresh “overt act” that restarted the statute of limitations under the continuing violation doctrine, as recognized in cases such as:

• Zenith Radio, 401 U.S. at 338–39;
• Klehr v. A.O. Smith Corp., 521 U.S. 179 (1997); and
• U.S. Airways, Inc. v. Sabre Holdings Corp., 938 F.3d 43 (2d Cir. 2019).

The Second Circuit emphasized the two requirements for a new, limitations‑restarting overt act:

1. It must be a new and independent act, not merely a reaffirmation or implementation of a prior decision; and
2. It must cause a new and accumulating injury to the plaintiff.

The panel characterized the key anticompetitive conduct as:

• The decision to adopt and enforce NCAA bylaws limiting compensation and mandating the Student-Athlete Statement; and
• The coerced transfer of broad NIL rights via that Statement.

Later commercial uses—licensing, broadcasting, or repackaging archival footage—were described as:

“a manifestation of the ‘overt act,’ the decision to enter the contract, rather than an independent overt act of its own.”

Relying on U.S. Airways and the summary order in SL‑X IP S.à r.l. v. Merrill Lynch, the court held that ongoing exploitation of rights obtained through a single allegedly unlawful contract is continuing damage, not a continuing violation. Accordingly, the continuing violation doctrine does not save the claims.

4.1.3 The “Speculative Damages” Exception Narrowly Applied

Plaintiffs next invoked a limited exception to the usual accrual rule, stemming from Higgins, Zenith Radio, and Klehr: in rare cases where the fact of injury was too speculative or unprovable at the time of the wrongful act, accrual may be deferred until damages become ascertainable.

The panel rejected this argument on two essential grounds:

1. Classic market exclusion: Exclusion from a market is a conventional, immediately cognizable antitrust injury. Citing Brunswick Corp. v. Riegel Textile Corp., 752 F.2d 261 (7th Cir. 1984), the court treated the plaintiffs’ exclusion from the NIL market as a loss that “gives rise to a claim for damages as soon as the exclusion occurs.”
2. Calculability of injury: Plaintiffs’ NIL had economic value at the time they signed; the NCAA’s ability to monetize NIL during their careers and immediately thereafter (as documented in the complaint itself) showed that loss was not “unprovable.”

The court expressly rejected the notion that a plaintiff may delay suing in order to see how profitable the defendant’s conduct turns out to be:

“The statute of limitations is not tolled simply in order to wait and see just how well the defendant does in the market from which he excluded the plaintiff. Otherwise it would be tolled indefinitely in a very large class of antitrust suits.”

Thus, even if modern NIL “markets and monetization structures” were unforeseen in detail, they were not so conceptually unforeseeable or unquantifiable as to delay accrual beyond four years.

4.1.4 Equitable Tolling: No Extraordinary Circumstances, No Diligence

Equitable tolling of federal limitations periods is reserved for “rare and exceptional circumstances.” The court drew on Phhhoto Inc. v. Meta Platforms, Inc., 123 F.4th 592 (2d Cir. 2024), A.Q.C. ex rel. Castillo v. United States, 656 F.3d 135 (2d Cir. 2011), and Watson v. United States, 865 F.3d 123 (2d Cir. 2017).

To qualify, plaintiffs must show both:

1. They diligently pursued their rights; and
2. Some extraordinary circumstance prevented timely filing.

The Second Circuit found neither:

• No extraordinary circumstances:
  • The plaintiffs’ youth at the time of signing the Statements was not unusual.
  • The NCAA’s long‑standing defense of its NIL policies was likewise “an entirely common state of affairs” for institutional defendants.
• No diligence, especially in light of:
  • Widely publicized antitrust class actions raising similar NIL/compensation issues—O’Bannon and Alston—filed years earlier;
  • The participation of some of the same players (or similarly situated players) in that earlier litigation; and
  • The principle from Bennett v. U.S. Lines, 64 F.3d 62 (2d Cir. 1995), that equitable tolling is disfavored when other plaintiffs have already brought similar suits.

Citing Pearl v. City of Long Beach, 296 F.3d 76 (2d Cir. 2002), the court concluded that plaintiffs failed to show it would have been “impossible for a reasonably prudent person” to discover and act upon their claims in time. Thus, equitable tolling was unavailable.

4.2 Laches and the Bar to Injunctive Relief

Even though the Clayton Act’s four-year limitations period applies directly only to damages claims, equity employs the doctrine of laches to police stale claims for injunctive or other equitable relief.

Under Ivani Contracting Corp. v. City of New York, 103 F.3d 257 (2d Cir. 1997), and Conopco, Inc. v. Campbell Soup Co., 95 F.3d 187 (2d Cir. 1996):

• Laches bars equitable claims where:
  • The plaintiff unreasonably and inexcusably delayed; and
  • The delay prejudiced the defendant.
• When the analogous statute of limitations has expired, a presumption of laches arises, and the burden shifts to the plaintiff to show why laches should not apply.

Here:

• The parties agreed that the Clayton Act’s four‑year limit is the proper analog.
• Because plaintiffs sued more than four years after their claims accrued, their request for injunctive relief came with a presumption of laches.
• Plaintiffs offered two main excuses:
  1. The NCAA “environment” reportedly barred athletes from obtaining counsel or negotiating NIL use while in school; and
  2. Alston in 2021 allegedly removed “practical legal impediments” to challenging these rules.

The panel rejected both rationales:

• The purported NCAA constraints did not prevent post‑college litigation.
• The existence of closely “paralleling” antitrust suits against the NCAA (some sharing plaintiffs with this case) showed that viable legal routes existed long before 2024.

The court adopted the district court’s view that plaintiffs “sat on their hands for more than a decade” despite obvious notice of their possible claims. As a result, the laches presumption was not overcome, and equitable relief was barred.

4.3 Unjust Enrichment as a Duplicative Claim under New York Law

4.3.1 Governing New York Principles

The district court, and the Second Circuit on appeal, applied New York unjust enrichment principles, citing:

• Diesel Props S.r.l. v. Greystone Business Credit II LLC, 631 F.3d 42 (2d Cir. 2011);
• Corsello v. Verizon New York, Inc., 18 N.Y.3d 777 (2012);
• E.J. Brooks Co. v. Cambridge Security Seals, 31 N.Y.3d 441 (2018);
• And the Second Circuit’s own application in Koenigsberg v. Board of Trustees of Columbia University, 2025 WL 1540252 (2d Cir. May 30, 2025) (summary order).

Under New York law, unjust enrichment requires:

1. Defendant was enriched;
2. At plaintiff’s expense; and
3. Equity and good conscience militate against permitting defendant to retain the benefit.

But critically:

“Unjust enrichment is not a catchall cause of action to be used when others fail. It is available only in unusual situations when, though the defendant has not breached a contract nor committed a recognized tort, circumstances create an equitable obligation.”

In other words, unjust enrichment is a gap‑filler. Where the same facts support a contract claim, a tort claim, or a statutory cause of action, courts frequently dismiss unjust enrichment as duplicative.

4.3.2 Duplicativeness in Chalmers

The plaintiffs’ unjust enrichment claim arose from the NCAA’s and conferences’ alleged:

• Coercive appropriation of NIL rights via the Student-Athlete Statement; and
• Commercial exploitation of footage featuring the plaintiffs without compensation.

But those same facts formed the basis for the Sherman Act and Clayton Act claims, and the plaintiffs sought the same core monetary relief: the value of NIL exploitation and lost market opportunities.

The Second Circuit cited Emic Corp. v. Barenblatt, 208 N.Y.S.3d 180 (1st Dep’t 2024), reiterating that unjust enrichment is barred when it:

“arises from the same facts and seeks the same damages.”

Because all the alleged wrongdoing was already captured by the antitrust theories, the unjust enrichment cause of action did not serve any independent function. On that basis, it was properly dismissed as duplicative, regardless of whether it might otherwise run into timeliness or preclusion issues.

4.3.3 Constructive Trust and Limitations

Plaintiffs attempted to rescue unjust enrichment by arguing that it uniquely supports a constructive trust remedy over NIL‑related revenues, which federal antitrust law does not specifically provide.

The panel rejected that attempt for two reasons:

1. Remedy does not create a cause of action: The mere availability of a different equitable remedy cannot convert an otherwise duplicative unjust enrichment claim into a valid, independent cause of action. If that theory were accepted, any duplicative unjust enrichment claim could be saved simply by requesting a constructive trust.
2. Constructive trust claims would themselves be time‑barred: Citing New York cases like Mattera v. Mattera and In re Estate of Thomas, the court observed that:
   • Constructive trust claims are subject to a limitations clock, typically beginning when the plaintiff is induced to sign the challenged transfer (here, the NIL authorization), and
   • Equitable remedies cannot be used to revive legal rights that are themselves time‑barred.

Therefore, constructive trust offered no way around the timeliness and duplicativeness defects.

4.4 Precedents Cited and Their Influence

While the preclusion doctrines from O’Bannon and Alston are mentioned, the Second Circuit’s reasoning heavily relies on broader antitrust and equity jurisprudence. Some of the key precedents and their roles are:

• Zenith Radio Corp. v. Hazeltine Research, Inc. (U.S.):
  • Established that antitrust claims accrue at injury and clarified the limited “speculative damages” exception.
• Higgins v. New York Stock Exchange (2d Cir.):
  • Restated the general accrual rule for antitrust claims used as a baseline.
• U.S. Airways, Inc. v. Sabre Holdings Corp. (2d Cir.):
  • Provided the framework for distinguishing between a continuing violation and continuing damages.
  • Deeply influenced the court’s conclusion that ongoing NIL use derived from a single, earlier rights transfer.
• Klehr v. A.O. Smith Corp. (U.S.):
  • Clarified that each new overt act can restart the limitations period, but not injuries from old acts outside the limitations period.
• Brunswick Corp. v. Riegel Textile Corp. (7th Cir.):

Although a Seventh Circuit case, Brunswick is cited approvingly in Chalmers for the notion that:

• Exclusion from a market is an immediately actionable form of antitrust injury; and
• Limitations are not tolled merely to see how profitable the defendant’s anticompetitive conduct becomes over time.

Other key precedents include:

• Phhhoto Inc. v. Meta Platforms, Inc. (2d Cir.):
  • Emphasized the “rare and exceptional” nature of equitable tolling in antitrust and similar contexts.
• Conopco, Inc. v. Campbell Soup Co. (2d Cir.):
  • Central in linking laches presumption to the expiration of an analogous limitations period.
• Corsello v. Verizon New York and E.J. Brooks Co. v. Cambridge Security Seals (N.Y. Court of Appeals):
  • Defined unjust enrichment as a non‑catchall remedy, limited to contexts where no other contract, tort, or statutory duty applies.

Collectively, these cases allowed the Second Circuit to resolve Chalmers without engaging deeply with the underlying merits of the NIL antitrust theories. The decision thus sits squarely within established antitrust-systems design: limitations, laches, and duplicativeness operate as early, rigid filters, even in novel or evolving economic contexts.

4.5 Practical Impact and Future Litigation

4.5.1 Limits on “Retroactive” NIL Antitrust Claims

In practical terms, Chalmers signals serious obstacles for:

• Former NCAA athletes whose eligibility ended before mid‑2016; and
• Any plaintiff who signed NIL‑related waivers or assignments long ago and now seeks to sue over ongoing commercialization of archival footage or images.

The court’s framework implies that:

• Claims accrue when athletes sign broad NIL authorizations under allegedly anticompetitive schemes, not when the NCAA later exploits the resulting rights.
• Claims filed more than four years after the last such signing are presumptively untimely, absent a clear and narrow ground for tolling (which Chalmers shows is unlikely).
• Claims for injunctive relief based on such old conduct face a strong presumption of laches.

This outcome is particularly consequential given that much of the NIL debate globally concerns historic footage (e.g., “March Madness Classic” games, documentary footage, archival highlight reels). Under Chalmers, the Second Circuit treats those uses as a long tail of damages stemming from a single, older injury.

4.5.2 Strategic Lessons for Plaintiffs and Defendants

For plaintiffs (athletes):

• The window to challenge NIL‑related restrictions or rights transfers is short—four years from the injury, absent unusual circumstances.
• Once a high‑profile antitrust case has been filed on analogous facts, equitable tolling becomes even less available; courts will expect potentially affected players to take notice.
• Layering unjust enrichment or constructive trust theories on top of statutory antitrust claims will not automatically provide a backdoor around limitations or preclusion.

For defendants (NCAA, conferences, media partners):

• Chalmers provides a roadmap to early motions to dismiss based on:
  • Time bars (statute of limitations);
  • Laches (for equitable relief); and
  • Duplicativeness (for unjust enrichment and similar equitable theories).
• The decision may encourage institutional defendants to rely more heavily on early procedural defenses rather than fully litigate substantive antitrust issues.

4.5.3 Relationship to Ongoing NIL Reforms

The substantive debate over whether the pre‑2021 NCAA compensation rules were lawful under the Sherman Act—addressed in Alston and other cases—is largely sidestepped here. The Second Circuit’s decision operates almost entirely at the procedural level.

Nevertheless, by constraining the availability of retroactive damages and ongoing injunctive relief for historical conduct, Chalmers indirectly:

• Reduces backward‑looking liability exposure for the NCAA and conferences for pre‑2016 NIL policies; and
• Refocuses attention on:
  • Prospective reforms and regulatory frameworks; and
  • Claims by current or very recent athletes whose injuries fall within the four‑year window or arise from new NIL regimes.

5. Complex Concepts Simplified

5.1 Continuing Violation vs. Continuing Damages

• Continuing violation: The defendant commits new unlawful acts over time, each independently actionable (e.g., renewing an illegal price‑fixing agreement every year).
• Continuing damages: The defendant commits one unlawful act (e.g., a coerced rights assignment), and the harmful economic consequences unfold over time (e.g., years of unpaid licensing revenue). The claim still accrues at the time of the original act.

In Chalmers, the court viewed the coerced NIL authorizations as the single unlawful act; subsequent uses of footage were continuing damages, not fresh violations.

5.2 Speculative Damages Exception

Sometimes, at the moment of a wrongful act, it is impossible to say whether the plaintiff has been injured, or to estimate the injury. In rare cases, courts allow the claim to accrue later, once:

• The injury becomes concrete; and
• Damages become reasonably measurable.

The Second Circuit held this was not such a case; exclusion from the NIL market and loss of the right to sell one’s own image were immediately cognizable and quantifiable injuries.

5.3 Equitable Tolling

Equitable tolling pauses a statute of limitations in extraordinary circumstances—for example, if:

• The defendant actively conceals the claim; or
• The plaintiff is prevented by forces beyond their control from filing.

Even then, the plaintiff must show diligent efforts to bring the claim once the obstacle is removed. In Chalmers, general institutional pressure and youth did not qualify as extraordinary, especially given public litigation on similar issues.

5.4 Laches

Laches is an equitable defense based on fairness, not a statute. It prevents a plaintiff from obtaining equitable relief (like an injunction) after:

1. Unreasonable delay in suing; and

Prejudice to the defendant from that delay (e.g., lost evidence, changed expectations, reliance on status quo).

When a parallel legal limitations period has expired, courts presume laches applies unless the plaintiff provides a strong reason otherwise.

5.5 Unjust Enrichment and Duplicativeness

Unjust enrichment allows recovery when:

• A defendant has wrongfully benefited at the plaintiff’s expense;
• But there is no enforceable contract or recognized tort theory covering that conduct.

If the same conduct is already actionable as, for example, an antitrust violation, fraud, or breach of contract, New York courts generally dismiss unjust enrichment as “duplicative.” It is intended for gaps—not to provide an alternative label when the primary claim is time‑barred.

5.6 Constructive Trust

A constructive trust is an equitable remedy, not a stand‑alone cause of action. Courts may impose it to:

• Prevent unjust enrichment where property was acquired by fraud, duress, or breach of a confidential relationship.

But:

• It is subject to its own limitations period (in New York, often six years from the wrongful transfer); and
• It cannot be used to revive a legal right that is already time‑barred.

In Chalmers, constructive trust could not circumvent the expired limitations for the underlying NIL rights transfers.

6. Conclusion

Chalmers v. NCAA is less about the substantive legality of the NCAA’s historical NIL practices and more about the structural role of procedural doctrines in federal antitrust and equity jurisprudence. The Second Circuit’s summary order:

• Reaffirms that antitrust claims accrue at the time of injury, even where damages will unfold over many years.
• Clarifies that ongoing use of rights obtained in a single, allegedly anticompetitive transaction is continuing damage, not a continuing violation, and does not restart the limitations clock.
• Applies the “speculative damages” exception narrowly, refusing to delay accrual on the theory that future NIL markets were unforeseeably lucrative.
• Demonstrates the stringent standard for equitable tolling of antitrust claims, especially when analogous litigation has already put potential plaintiffs on notice.
• Shows how laches can bar injunctive relief once the analogous statute of limitations is exceeded, erecting an additional barrier to stale claims.
• Reiterates that unjust enrichment cannot be used as a catch‑all to salvage time‑barred statutory claims when it rests on the same facts and seeks the same recovery.

In the broader legal context, particularly amid ongoing NIL reforms and debates over athlete compensation, Chalmers underscores that:

• Even where the underlying policies are controversial or evolving, federal courts will strictly enforce limitation periods and equitable defenses to promote finality and predictability; and
• Former athletes seeking retroactive compensation for historic NIL exploitation must navigate not just difficult substantive antitrust terrain, but also a set of rigorous procedural gates that close quickly after graduation.

Though non‑precedential, the order will likely serve as a persuasive roadmap in the Second Circuit and beyond for resolving similar retroactive NIL and antitrust claims at the pleading stage, emphasizing that time and diligence are as critical as the merits in complex sports‑antitrust litigation.