Last Wednesday, the U.S. Court of Appeals for the 9th Circuit ruled in the much publicized O’Bannon case that pitted former NCAA athletes against the association on compensation rules for athletes’ name, image and likeness (NILs).Specifically, the 9th Circuit had before it two issues: (1) if the NCAA is immune from antitrust scrutiny; and (2) whether increases in monetary benefits to NCAA athletes, both to full cost of attendance limits and cash payments for licensing of athlete NILs, are valid alternative …