issue of Milwaukee Braves: what aspects of baseball can state antitrust law regulate? Judge Gerald Bard Tjoflat wrote that the amount of teams that play was another decision "integral to the business of baseball" and thus beyond the reach of federal law. A paragraph in Flood that briefly addressed the state antitrust issue was, while "hardly a model of clarity", led him to accept MLB's theory that under the Supremacy Clause, "the Supreme Court's Commerce Clause jurisprudence, when applied to professional baseball, must be read to establish a unique per se rule that prohibits the application of state antitrust laws when the federal exemption is triggered ... [F]ederal law establishes a universal exemption in the name of uniformity." In his conclusion, Tjoflat conceded that while "[t]he exemption was founded upon a dubious premise, and it has been upheld in subsequent cases because of an equally dubious premise", and it was thus understandable that Florida should seek a more limited exemption, that was nevertheless the prerogative of the Supreme Court or Congress. Right Field Rooftops v. Chicago Cubs In 2013 the owners of two of the Wrigley Rooftops, the viewing areas erected atop privately owned buildings on the streets adjacent to Wrigley Field, from which Chicago Cubs games and other events at Wrigley Field can be seen, sued the team alleging its owners, the Ricketts family, had been indulging in anticompetitive practices to force the sale of some of the remaining rooftops to the team in violation of an earlier agreement. The plaintiffs anticipated the team's likely invocation of the baseball antitrust exemption by arguing that it applied only to MLB and not individual franchises. Judge Virginia M. Kendall of the Northern District of Illinois rejected that argument in denying them a preliminary injunction, noting that Toolson had affirmed Federal Baseball with a team as defendant, as well as the Cincinnati Reds in its companion case, Corbett v. Chandler. Scope of exemption Since Flood lower courts have divideed over whether baseball's antitrust exemption was limited in scope to the reserve clause (the minority position, taken by only two courts) or covered baseball generally. To resolve this question, some courts have generally turned the inquiry to the role the reserve clause played in the original Federal Baseball case, or looked to the text of the three Supreme Court decisions establishing and affirming the exemption. Broad "business of baseball" exemption The first court