receive draft picks as compensation. In recent years, many teams have opted not to exercise their right to designate the franchise tag. NBA The National Basketball Association went through several phases of compensation and other arcane provisions before reaching almost unrestricted free agency. The first player in that league—and the first American major-league athlete—to challenge the reserve clause was Rick Barry. In 1969, he wanted to leave the San Francisco Warriors after his second season to play for the Oakland Oaks, who were coached by his father-in-law, Bruce Hale. After a court upheld it, Barry sat out a season before joining the Oaks. NHL The reserve clause was the basis for the NHL's injunction against the large number of players who had signed with the rival World Hockey Association in 1972, with all but one—against Chicago Black Hawks star Bobby Hull—ultimately thrown out by lower courts. The appellate court, however, sided strongly with the WHA and Hull, calling the NHL's business practices monopolistic, conspiratorial, and illegal. While the reserve clause was not explicitly struck down, the court did effectively block any further injunctions based on the reserve clause, rendering it useless. (The WHA, meanwhile, voted at its founding to abolish the reserve clause.) The end of the reserve clause in hockey remains a significant part of the WHA's legacy, as it ultimately resulted in the evolution of the NHL's modern free agency system. The highly contentious negotiations between National Hockey League owners and players that led to a lockout, wiping out the entire 2004–05 NHL season, were in part about free agency; the previous system precluded unrestricted free agency before the player reached 31 years of age. Most younger hockey free agents were restricted free agents whose teams could retain them by matching an offer from another club or making a "qualifying offer", which usually consisted of a ten percent raise above the pay in the former contract. Following the 2004-05 lockout, owners eventually agreed to phase in a much lower age for unrestricted free agency (27 years of age or 7 years in the NHL, whichever comes first) in exchange for the players meeting owners' principal demand in the new NHL Collective Bargaining Agreement—an overall salary cap. Nevertheless, the league demanded the re-imposition of the 31-year-old threshold for free agency in the most recent lockout, but when union responded by threatening to disclaim interest and file antitrust suits against