Knicks v. Raptors in the Legal Arena

The 21st century New York Knicks have seen quite their share of off-court shenanigans. In 2006, the Knicks had a massive brawl against the Nuggets that resulted in several suspensions.(1) In 2017, Knicks legend Charles Oakley was involved in a confrontation with arena staffers that led to Oakley’s arrest and a public feud with Knicks’ owner, James Dolan.(2) And then, there is the well-documented incestuous relationship between the team’s standing president, Leon Rose, and the basketball division at Creative Artists Agency (CAA), which he co-launched himself, presenting a curious link between the Knicks and CAA clientele.(3) These incidents, among others, have certainly held the attention of Knicks fandom over the last 24 years, even as the team has continuously struggled to make it out of the opening round of the National Basketball Association (NBA) playoffs.(4)

The latest off the court controversy is new and exciting even for this storied Knicks franchise. This time, the team has initiated a lawsuit against its NBA division rival — The Toronto Raptors. As Baxter Holmes of ESPN documented in his recount of the dispute, the Knicks alerted the Raptors of their claims on Thursday, August 17th 2023. The Knicks chief legal counsel sent a letter to Larry Tanenbaum, owner of the Raptors, detailing their discovery of a conspiracy between the Raptors and Ikechukwu Azotam, a former Knicks employee poached by the Raptors.(5)   

Azotam, the former Quinnipiac Bobcats basketball standout, first joined the Knicks in November of 2020 as an assistant video coordinator after being forced into retirement from play at just 24-years-old.(6, 7) As a Bobcat, Azotam had led the team in his senior season, 2014–15, and was named to the All-MAAC First Team. However, his college career was plagued by health concerns that no one truly understood at the time. In four years at Quinnipiac, he was reported to have suffered repeated anxiety attacks accompanied by sudden shortness of breath and lightheadedness.(7) After just one season playing overseas in Spain, a routine physical in December 2015 revealed an irregular heartbeat, connecting the dots to Azotam’s unusual symptoms and thereby ending his professional playing career. Azotam then went back to school and received a master’s degree from the University of Texas at Austin, and coached there for one season before joining the Knicks organization in 2020.(8) In the summer of 2021, Azotam was promoted by the Knicks to Director of Video/Analytics/Player Development Assistant and became responsible for “planning, organizing and distributing all video scouting responsibilities for the Knicks coaching staff.” In the summer of 2023, the Raptors convinced Azotam to leave the Knicks and join their revamped coaching staff.(9)     

The Knicks’ preliminary letter accused Azotam of taking with him and sharing with the Raptors a set of proprietary information obtained from his time with the Knicks. They demanded the Raptors destroy the stolen information and preserve evidence of the communications between them and Azotam, while simultaneously threatening further investigation and legal action. The Raptors replied the very next day. Peter Miller, the Raptors chief legal officer, stated they would cooperate with the investigation, but did not know what information Azotam had relating to his work with the Knicks. While the Raptors had hoped to settle the matter in private, the Knicks used the proceeding weekend to prepare a 21-page complaint that they filed on Monday, August 21st in federal district court for the Southern District of New York.(10)

The Knicks’ complaint named the Raptors parent company, Maple Leaf Sports & Entertainment Ltd., as well as new head coach Darko Rajaković, player development coach Noah Lewis, a set of unknown Raptors employees, and Azotam as defendants in the conspiracy. The document alleged that Azotam had breached the confidentiality clause included within his Knicks’ Employment Agreement by forwarding proprietary information from his Knicks email account to his personal Gmail account and subsequently forwarding it along to other Raptors defendants. Specific file names, types, and descriptions were included in the complaint to demonstrate the legitimacy of the claims. In total, the Knicks allege over 3,000 files were transferred, including “scouting reports, play frequency reports, a prep book, and a link to third-party licensed software.”(11) Notably, the Knicks framed the hire of Azotam as a ploy to steal from the Knicks in combatting their own organizational incompetency. In doing so, they repeatedly attacked the capability of Rajaković.(12)

While in fact a first-time NBA head coach, Rajaković is no stranger to leading basketball teams. Coaching since his teenage years in his native Serbia, Rajaković has long been a student of the game. He received his training at the Serbian Basketball Academy in Belgrade and coached for several years around the world. Rajaković began his NBA career as a scout and consultant for the San Antonio Spurs in 2012-13. Soon after, he was hired by the Oklahoma City Thunder to coach their Tulsa affiliate in the NBA G-League, before spending a combined nine years as an assistant across the Thunder, Phoenix Suns, and Memphis Grizzlies. Although Rajaković now has his first opportunity to lead an NBA team with the 2023-24 Raptors, this is hardly his first stop on the coaching mill.(13)

Even so, the Knicks seem to have attacked Rajaković to ascribe motivation to the defendants’ alleged actions. In the 21-page complaint, the Knicks called out Rajaković seven different times for his stature as a first-time NBA head coach. The Knicks mixed up their language, using the phrases “no prior experience,” “novice,” and “non-traditional path,” to guide the point to their final jab: “Defendant Rajaković did not have his own [organizational structure and coaching method], so he chose to exploit the Knicks’ methods.” The complaint alleges eight counts across the defendants, including violations of both the federal Computer Fraud and Abuse Act (“CFAA”) (18 U.S.C. § 1030) and Defend Trade Secrets Act (“DTSA”) (18 U.S.C. § 1832). In turn, the Knicks seek permanent injunctions ordering the Defendants to refrain from engaging in further acts of misappropriation of their material, using, copying, reviewing, or disclosing any of the material they obtained, and accounting for any and all of the acquired information. In addition, they seek a judgment finding the defendants’ actions were willful and malicious, barring Azotam from benefitting from his acts, and a series of damage awards.(14)

But why would the Knicks even choose to resolve this suit in court rather than within the confines of the NBA infrastructure they share? Afterall, ESPN research found only one other instance of an NBA team suing another. In 1977, the Nets and Knicks clashed in a unique federal antitrust suit related to the Nets attempted move from Long Island to New Jersey, but the teams eventually settled.(15)

In their initial legal response, the Raptors’ side called this suit “baseless” and a “stunt” in asking the judge for a dismissal.(16) The Raptors have repeatedly requested that NBA Commissioner Adam Silver settle the dispute outside of the courtroom.(17) They have claimed that the NBA constitution governs the dispute and calls for arbitration by the league.(18) However, the Knicks have rejected this proposal, arguing that Silver’s relationship with Raptors’ owner, Larry Tanenbaum, poses a conflict of interest.(19) In 2022, Tanenbaum was re-elected as chairman of the NBA board of governors, and thus effectively continues to serve as Silver’s boss.(20, 21) In fact, according to Holmes’ reporting, Silver has even described Tanenbaum as “not just my boss as the chairman of the board of governors, but he's very much a role model in my life.” If that was not conflict enough to keep the dispute in court, the Knicks argue further that the maximum penalty Silver could subject upon the Raptors would be $10 million, a sum the Knicks do not believe would meet the damages they seek. Not only is the issue of the Silver/Tanenbaum relationship at play, but another contentious link hangs over the case as well: one between Raptors president Masai Ujiri and Knicks owner James Dolan. Multiple player-trade negotiations between Ujiri-led organizations and Dolan’s Knicks have left the sides displeased, and Ujiri has refused to join forces with Dolan despite long-standing Knicks’ interest. This strain in the leaders’ relationship certainly lives on underneath the conflict now facing the organizations.(22)              

On December 11th, the Raptors, for the first time, warned of a potential countersuit. Maple Leaf Sports & Entertainment Ltd. wrote in their latest filing that they reserve the right to bring an action against the Knicks for the defamatory statements they made. Again, they argue that it would be more appropriate for Adam Silver to find a resolution for the teams instead of resolving the case in federal court. In their eyes, “this case is only about NBA competition.”(23) But as of January 2024, there have been no further updates as the case awaits further proceedings in federal court.

Interestingly, the two sides have not let their legal drama stand in the way of conducting business as usual. Just two and a half weeks after the Raptors’ latest filing was entered, on December 30th, 2023, the Knicks and Raptors collaborated on the first trade between the franchises in ten years. The Knicks acquired 26-year-old forward OG Anunoby along with forward Precious Achiuwa and guard Malachi Flynn, in exchange for Canadian native RJ Barrett, guard Immanuel Quickley, and a 2024 second-round pick.(24) Basketball commentators, including The Athletic’s Zach Harper and SBNation’s Ricky O’Donnell, have asserted this was a strong deal for both sides; however, one is left wondering: Could the Knicks have gotten a better deal had the suit not loomed over the negotiations?(25, 26)