The Influence of Name, Image and Likeness Opportunities on Football Recruiting

By Maggi Driscoll

The debate over whether to allow student-athletes to make money from their name, image, and likeness (NIL) had been heating up for years. Many athletes view NIL rights as rights they deserve, while the National Collegiate Athletic Association (NCAA) considers NIL rights a threat to the amateur nature of college sports.1 This argument came to a head during the summer of 2021, when the heavily-pressured NCAA changed its policy to allow NIL deals to be made, in accordance with numerous state laws.2

This change has led many universities, including the University of Southern California (USC), to make NIL a focal point in football recruiting. As the landscape continues to change, USC hopes to leverage its location in Los Angeles, and the entertainment opportunities that come with it, to attract top talent and repair its struggling football program.3 But USC’s recent embracing of NIL does not come without a struggle, as these sudden changes to NIL policy create continuing uncertainty over the future of NIL and collegiate sports.

The Beginning of Name, Image and Likeness Money-Making

Before July 1, 2021, there were strict rules preventing college student-athletes from making money through their participation in sports.4  Former NCAA Bylaw 12.5.2 stated that student-athletes would not be eligible to participate in intercollegiate athletics if they permitted or accepted any payment for the use of their NIL to advertise, recommend or promote a product or service.5 Athletes would also be ineligible if they received payment for endorsing a product or service through their use of that product or service.6 The penalties for violating these regulations were harsh; schools could be fined and players could be prohibited from competing if students were caught accepting money in exchange for use of their NIL.7

One of the most famous examples of NCAA sanctions for NIL violations involved Reggie Bush and the 2004-2005 USC football program. During Bush’s time at USC, marketing agents allegedly provided thousands of dollars in inducements in an attempt to entice Bush to sign with their agencies. These inducements included cash, housing for Bush’s family, hotel rooms and travel accommodations.8

After Bush’s time at USC, and a subsequent years-long investigation by the NCAA, the Trojans football program was barred from participating in bowl games for two seasons and was docked ten scholarships in each of the following three seasons for failing to properly monitor athletes receiving inducements.9 Bush was found to have violated the NCAA’s amateurism rules, and the program was required to vacate all victories in which Bush participated between December 2004 and 2005—including the 2004 title-winning Orange Bowl victory.10 The scandal also resulted in Bush becoming the first ever Heisman Trophy recipient to return the award, as all players must comply with NCAA rules to be eligible for the honor.11

For years, the NCAA argued that its strict rules on student-athlete compensation were necessary because amateurism is essential to consumer demand for college sports—it distinguishes collegiate athletics from professional leagues.12 During that time, student-athletes who chose, or were required to play, at the collegiate level before playing professionally likely missed out on substantial revenue from NIL deals. In particular, USC students could have benefitted significantly from the unencumbered use of their NIL rights due to the school’s proximity to Los Angeles; a city known for capitalizing on the intersection of sports and media. However, in June 2021, students saw rules against NIL activities suddenly reversed after the NCAA lost a landmark court case that changed the landscape of collegiate sports.

The Alston Decision

On June 21, 2021, the Supreme Court struck down NCAA rules limiting education-related benefits offered to student-athletes in National Collegiate Athletic Association v. Alston.13 In a unanimous decision, the Court held that the rules violated antitrust law under the Sherman Act, thereby opening the door to colleges and universities looking to provide greater incentives for current and prospective student-athletes.14 Although the Alston decision did not directly address NIL rights, it immediately put pressure on the NCAA to either alter its established stance on NIL or face additional suits brought by student-athletes eager to see how far the courts would go to protect players’ rights.15 Turning the heat up even further, six different states enacted pro-athlete NIL-centered legislation set to go into effect on July 1, 2021.16

Just nine days after the Supreme Court’s ruling in Alston, the NCAA released new, interim rules suspending its previous ban on NIL deals.17 The new rules are deceptively simple: players may engage in NIL activities that are consistent with state law and, if desired, may do so through a professional services provider.18 Schools, state law, and athletic conferences may dictate whether players need to report their NIL activities, but the NCAA does not independently require them to do so.19

California’s Fair Pay to Play Act and NIL Deal Disclosure

In an effort to put California schools on equal footing with schools in other states that had enacted NIL laws earlier in 2021, Governor Gavin Newsom pushed forward the effective date of California’s Fair Pay to Play Act from 2023 to September 1, 2021.21 The act officially bars any postsecondary institution, conference or other organization with authority over intercollegiate athletics from prohibiting a California student-athlete from making money off their NIL.22

The Fair Pay to Play Act requires student-athletes who engage in NIL contracts to disclose those contracts to an official at their university.23 But unlike the Act, the NCAA rule does not prescribe a punishment for failing to disclose deals to a student’s university. In fact, the NCAA does not even label non-disclosure as a violation, nor does it specify which university official must oversee disclosure.24

 “State law says [student-athletes] have to disclose [NIL contracts], and many do. But I’m sure there are things that I haven’t seen [that] should have been disclosed, but they weren’t, and that’s not an NCAA violation,” said Siemer.25 “I would say the California law is very broad. All you’ve got to do is tell your athletic department what you’re doing, but we don’t have any recourse to get [student-athletes] to do it.”26

 The Fair Pay to Play Act does not currently require universities to report non-disclosure to the state, so unless the government takes steps to audit or inspect a specific institution’s NIL records, compliance officers do not have much power in enforcing the act’s disclosure requirement.27

A lack of disclosure may ultimately hinder USC recruiting, as coaches and staff miss out on figures that could make or break an athlete’s decision to invest their future in the university. Because coaches do not know how much their players are making, they cannot give prospective players an accurate estimate of the amount of money potential recruits could make by coming to USC.28 

Even when NIL deals are disclosed to USC’s Compliance department, the terms of those contracts are kept from coaching staff. “Coaches want to see that information, but [the compliance department says] we can’t give it to you, or we won’t give it to you,” said Siemer. “We’re just not comfortable.”29

There is nothing legally prohibiting Siemer from disclosing deals to coaches, but if an agent requests that a contract stay confidential, the department has a powerful incentive to comply with the request: the desire to maintain strong relationships with these agents, who are often among LA’s best entertainment representation.30  Maintaining those relationships could be incredibly important to USC, as matching players with credible agents reduces the chances that the school’s young athletes will be taken advantage of when signing NIL deals.31

In addition to USC’s voluntary disclosure woes, the University may face a greater disadvantage than California public schools when trying to obtain contract information. Because public institutions are subject to the California Public Records Act,32 a records request could likely be made when athletes or a school’s compliance department withhold figures, such as the average NIL compensation that a school’s football athletes receive or the median revenue generated from players’ deals—information that may be useful in recruiting. Although coaching staff may be hesitant to go through such official channels, it is a useful bargaining tool that USC does not possess as a private university.

Despite NIL disclosure issues, USC likely still has more leverage than most other universities when it comes to NIL, as the institution is one of the most recognizable collegiate brands in the nation and is located in a city known as the global entertainment capital.  

Los Angeles as an Entertainment Capital

“The ceiling on [NIL] is much higher [in Los Angeles] than a ton of these other places because of the amount of money out here, especially in entertainment and sports,” said USC Football Director of Recruiting Strategy Marshall Cherrington.36 “It’s the biggest media market with a major college football team and the second biggest media market in the US.”37

Big-name professional athletes have seen the fruits of relocating to Los Angeles while playing at the most elite level. The rich entertainment industry in LA provides athletes with the opportunity to expand into film and music even as they further their athletic careers. Since joining the Los Angeles Lakers, LeBron James has grown his portfolio to include major projects like the film Space Jam: A New Legacy,38 and superstar Kawhi Leonard has launched a music career during his time on the Los Angeles Clippers.39

Looking specifically at USC, football legends Matt Leinart and Reggie Bush have translated their collegiate and professional athletic careers into full-time commentating positions with Fox.40 In the NIL space, former USC long snapper Jake Olson and his college roommate Daniel Hennes co-founded Engage, a platform designed to streamline speaking engagements, sweepstakes setup and NIL deals for a wide array of athletes.41

“The benefit of being [in Los Angeles] is that there’s a lot going on. A lot of our agent colleagues are in LA—it’s obviously a recruiting and innovation hotbed,” said Hennes. “Having the network that we have in LA helps us do deals nationally.”42

One could expect USC Athletics to use the professional success experienced by former student-athletes as a selling point to entice star recruits to the school’s struggling football program.

 Discussing NIL-oriented recruitment possibilities in light of the faltering program, Cherrington stated that  “[o]n-field performance is the most important thing at the end of the day, … but I think the lure and the opportunity that players have here is appealing because they have the chance to bring us back to [championship] level … all while having a strong chance at being remembered for bringing the program back.”43

Top USC recruits have already begun to see some success in Los Angeles’s thriving entertainment market. Freshman cornerback Ceyair Wright, who starred alongside LeBron James in Space Jam: A New Legacy, recently signed a deal with digital sports media company Overtime to grow his entertainment brand.44 Since signing, Overtime has launched a digital series titled ‘Dual Threat,’ which chronicles Wright’s collegiate athletics experience.45 Star quarterback transfer Caleb Williams has also signed massive NIL deals since committing to USC, including partnerships with Fanatics46 and Beats By Dre,47 both of whom welcomed him to LA in their announcements.48 William’s most Los Angeles-centered deal is a long-term agreement with Beverly Hills real estate private equity fund, Hawkins Way Capital, United Airlines47 and American Eagle Outfitters,48 and he has created his own brand logo.49

 “NIL is the greatest deal and opportunity for brand marketers ever because you’re getting college kids with hyper-engaged followings generally in a very specific, easy-to-target market,” said Hennes, “And the amount of money you have to spend to get a post or endorsement isn’t nearly what you have to spend to get a professional athlete or an influencer to post the same thing.”50

 But USC isn’t new to the NIL game. Recruiting coordinators have been using the potential for future NIL opportunities in presentations for the last few years, as they correctly predicted that the NCAA would back down in the face of looming state laws.51

 “Since [the California Fair Pay to Play Act] was passed in 2019 … there had been overhanging rumors that [NIL] was going to become a reality in college athletics,” said USC Director of Player Personnel Spencer Harris. “I’ve been working on this for the last year and a half.”52

In another example of foresight into potential NIL profits in Los Angeles, USC launched the in-house creative lab BLVD Studios in October 2020 to better promote the images of student-athletes.53 The studio hopes to corner the collegiate entertainment market by producing photography, video, podcasts and mixed media content for individual athletes looking to improve their revenue stream.54

 “The best players want to go to the best places that offer them the best opportunities, and in our opinion, NIL is very unique to Los Angeles,” added Harris.55 

The existence of such a program helps remove any intermediaries that could potentially exploit or swindle athletes out of monetary opportunities by bringing the operation in-house.56 It is one example of the steps USC has taken to offer its athletes further protection beyond current legislative safeguards.

NIL and the Power of Los Angeles Lawyers and Agents

Although the NCAA now allows student-athletes to contract with agents, its decision did not come with guidance or safeguards to protect student-athletes from predatory agents looking to take advantage of young stars.57

 “At the end of the day, [student-athletes] are kids, … and if they don’t have the proper support and the right people in their corner, they can be taken advantage of,” said Harris. “These 18- to 22-year-olds who really have had no exposure to this space don’t really know what they’re dealing with.”58

 “We have seen some terrible contracts come across our desks,” said Hennes, “And there are definitely kids who don’t have [help] who get taken advantage of and that’s really disappointing to see.”59 California’s Fair Pay to Play Act is a bit more specific when it comes to who may represent an athlete. The law requires all agents contracting with student-athletes to be licensed by the state and to abide by the federal Sports Agent Responsibility and Trust Act.60

 USC has experience dealing with agents of superstar players. Prior to July 1, 2021, the University ran an agent-registration program that created a list of reputable representation for student-athletes to reference once their NCAA eligibility had run out and they were ready to move on to the next level of their careers.61 “Some of our top players have signed [with] marketing agents, and we encourage that because at the end of the day, we just want [our players] protected and to be compensated for all the opportunities they deserve, but in the smartest way possible,” said Harris.62

 USC has also paired with Altius Sports Partners to provide its student-athletes with basic legal literacy when it comes to brand building, management, and contract analysis.63 Altius is a national, NIL-resource program provider currently spearheaded by CEO Casey Schwab64 and COO Courtney Brunious,65 both of whom are USC Gould School of Law alumni and former University faculty members. As NIL rules and customs continue to change, Altius aims to help USC athletes navigate LA’s entertainment space, providing what USC views as an asset to recruiting that few other universities can match.66

 But despite USC’s significant experience with star athletes and the steps the university has taken to lay the groundwork for brand success, like all universities, USC will likely have to grapple with future legislative changes to the current legal status of NIL.  

The Volatile Future of NIL

 How involved a school is willing to get in its players’ NIL opportunities has been an institutional call, with some universities essentially announcing a free-for-all for their players, and others taking a more conservative approach to how they facilitate deals. USC is staunchly on the cautious side, and a primary reason for that originates from the university’s legal experience and belief that the state of NIL is bound to shift dramatically in the coming years.67

“It’s a feeling-out process,” said Harris. “It’s been a little bit slower than expected, but I really think it’s because the structure that was put in place by the NCAA and the timing didn’t give schools, and even players, a lot of opportunities to adjust and prepare.”68

The NCAA was just as rushed as universities and athletes when it came to creating NIL policies. The Alston decision made it clear that the Supreme Court would likely stand in support of student-athletes in future litigation. That gave the NCAA little more than a week to put together any new policies before many state laws went into effect on July 1, 2021.69 Due to this rush, the NCAA emphasized that their NIL policy was an interim one until either the association or the federal government adopted new legislation.70 “We are still waiting to see where the lines are going to be drawn from an NCAA perspective so that we won’t trip over them,” said Siemer.71

Due to the lack of clarity from the NCAA, the federal government has begun to consider various bills to regulate NIL. Perhaps the most comprehensive bill concerning NIL is the College Athletes Bill of Rights, introduced by Senators Cory Booker, Richard Blumenthal, Kirsten Gillibrand and Brian Schatz.72 The bill was designed to guarantee equitable compensation, provide enforceable safety standards, and improve educational opportunities for collegiate athletes, but it has gained little traction since it was first put forward in December of 2020.73

In February 2021, Senator Jerry Moran proposed the Amateur Athletes Protection and Compensation Act, which would allow players to profit from their NIL both before and during college. The act would also make it possible for athletes who declare for a draft to retain their eligibility as long as they do not accept compensation from a professional league, team or agent.74

 Additionally, Senator Christopher Murphy and Representative Jamaal Bowman introduced the College Athlete Right to Organize Act on May 27, 2021, which would classify student-athletes as employees and establish collective-bargaining for student-athletes.75 As of June 23, 2021, seven different NIL-centered bills have been put forward and are being considered in some capacity by the House or Senate.76

 Despite both the NCAA and student-athletes expressing support for federal legislation addressing NIL, it will take time for representatives to compromise on the bill they believe is best for collegiate sports. In addition to the time required to pass a substantive federal NIL law, college teams will also need time to grasp the full impact that NIL legislation has on their recruiting capabilities. As laws change, so will schools’ tactics for attracting players aiming to become double threats in both sports and entertainment.

 “It might be a few years before we see what [the impact of NIL] is, but inherently, it’s easy to sell Southern California and all of the opportunities from an entertainment perspective,” said Siemer.77

“You’ll slowly start to see a change, and more kids will start to see it. You start to see success on the field, you start to see success off the field in a space like NIL, and it becomes even more appealing for different kids,” said Cherrington. "That’s when you really get the onslaught of talent. But that takes time.”78

As schools try to navigate the new legal status of NIL, brands may also begin to slow their offerings while the industry develops and companies learn which athletes have made their sponsorships worthwhile.

“I think traction will not always be there like it is right now. It’s fresh and interesting, but at the same time, when people are spending money, they want to be making money, or they need to be getting something out of it,” said Siemer.79 

USC’s struggles on the field in recent years may also play a role in the team seeing fewer NIL deals than more successful LA-based teams, or even winning teams based in smaller markets.

“USC can capitalize on [NIL], … and it’s something they’re focused on, but at the end of the day, you still have to win,” said Hennes.80

Although USC football hasn’t found success the last few seasons, that may change with the hiring of former Oklahoma University coach Lincoln Riley.81 Riley has brought a wave of top transfers and recruits,83 as well as an iron clad coaching staff,84 to Los Angeles in an effort to revive the school’s program.

USC is in a prime position to capitalize on these new NIL rules: the school can market its access to an entertainment capital to top players, and it has the potential to build up the football program under respected new leadership. With more success on the field, USC may see stronger NIL deals and better recruiting classes. However, it remains to be seen whether the lack of legal clarity and protections will be detrimental to young players or if the NIL landscape will remain fruitful long enough to give USC the chance to improve on the field.

end notes

1. NCAA v. Alston Signals Peril for the NCAA’s Amateurism Defense but Implications for Antitrust Go Well-Beyond Collegiate Sports, Crowell & Moring (June 23, 2023), https://www.crowell.com/NewsEvents/AlertsNewsletters/all/NCAA-v-Alston-Signals-Peril-for-the-NCAAs-Amateurism-Defense-But-Implications-for-Antitrust-Go-Well-Beyond-Collegiate-Sports [hereinafter NCAA v. Alston Signals Peril].

2.     See Michelle Brutlag Hosick, NCAA Adopts Interim Name, Image and Likeness Policy, NCAA (June 30, 2021), https://www.ncaa.org/about/resources/media-center/news/ncaa-adopts-interim-name-image-and-likeness-policy.

3.     See Interview with Marshall Cherrington (2021) (on file with journal).

4.     See NCAA v. Alston Signals Peril, supra note 1.

5.     National Collegiate Athletic Association, 2019-2020 NCAA Division I Manual 77 (2019), https://www.ncaapublications.com/productdownloads/D120.pdf.

6.     Id.

7.     See Gary Klein & David Wharton, NCAA Sanctions Could Cost USC Millions, L.A. Times (July 10, 2010), https://www.latimes.com/archives/la-xpm-2010-jun-10-la-sp-0611-usc-ncaa-sanctions-20100611-story.html.

8.     Gary Klein & Mike Hiserman, The USC Case: What Happened When, L.A. Times (July 10, 2010), https://www.latimes.com/archives/la-xpm-2010-jun-10-la-sp-0611-usc-timeline-20100611-story.html.

9.     Chris Mottram, USC Sanctions: Full Outline of NCAA's Punishments Includes Football, Basketball, Tennis Programs, SBNation (June 10, 2010), https://www.sbnation.com/2010/6/10/1511711/usc-sanctions-full-outline-ncaa-punishments-football-basketball-tennis.

10.  Lynn Zinser, U.S.C. Sports Receive Harsh Penalties, N.Y. Times (June 10, 2010), https://www.nytimes.com/2010/06/11/sports/ncaafootball/11usc.html.

11.  Mihir Bhagat, Reggie Bush Heisman Scandal: Former USC Star Running Back Returns Heisman Trophy, Bleacher Report (Sept. 14, 2010), https://bleacherreport.com/articles/462705-reggie-bush-heisman-former-usc-star-returns-trophy-for-ncaa-ineligibility.

12.  See NCAA v. Alston Signals Peril, supra note 1.

13.  See Nat’l Collegiate Athletic Ass’n. v. Alston, 141 S.Ct. 2141, 2147 (2021).

14.  Marc Edelman, What Happens Now that the Supreme Court Has Decided Alston v. NCAA?, Forbes (June 22, 2021), https://www.forbes.com/sites/marcedelman/2021/06/22/what-happens-now-that-the-supreme-court-has-decided-alston-v-ncaa/?sh=7ebfb86f7393.

15.  Id.

16.  Bill Bender, Name, Image and Likeness (NIL) and July 1: How Much Change Is Coming to College Football?, Sporting News (June 25, 2021), https://www.sportingnews.com/us/ncaa-football/news/name-image-and-likeness-nil-and-july-1-how/2jie2fdxbk331c1nvbnp33lf5.

17.  See Hosick, supra note 2.

18.  Id.

19.  Id.

20.  Interview with Kyle Siemer (Sept. 29, 2021) (on file with journal).

21.  Evan Symon, Gov. Newsom Signs Student Athlete Compensation Law to Move Up Start Date, Cal. Globe (Sept. 1, 2021), https://californiaglobe.com/articles/gov-newsom-signs-student-athlete-compensation-law-to-move-up-start-date/.

22.  Id.

23.  Cal. Educ. Code § 67456 (West).

24.  See id.

25.  See Interview with Kyle Siemer, supra note 20.

26.  Id.

27.  See id.; Cal. Educ. Code § 67456 (West).

28.  See Interview with Spencer Harris (Sept. 30, 2021) (on file with journal).

29.  See Interview with Kyle Siemer, supra note 20.

30.  Id.

31.  Id.

32.  California Public Records Act, Univ. of Cal. Libraries, https://libraries.universityofcalifornia.edu/content/california-public-records-act.

33.   Ann-Christine Diaz, City Spotlight: L.A. Isn't Just an Entertainment Town, Ad Age (July 24, 2018), https://adage.com/article/cmo-strategy/spotlight-los-angeles/314285.

34.  Sports Agencies by State: Best Places to Get a Sports Management Job, Univ. of Kan. (Sept. 7, 2021), https://onlinesportmanagement.ku.edu/community/sports-agencies-by-state-best-places-to-get-a-sports-management-job.

35.  Id.

36.  Interview with Marshall Cherrington, supra note 3.

37.  Id.

38.  Jenna West, LeBron James, Bugs Bunny, and More: Everything We Know About 'Space Jam 2,' Sports Illustrated (June 20, 2019), https://www.si.com/nba/2019/06/20/space-jam-2-cast-director-premiere-date-lebron-james-rumors.

39.  Chris Cwik, Kawhi Leonard Working on Music Project, Will Send Proceeds to Mamba and Mambacita Foundation, Yahoo! Sports (May 5, 2021), https://sports.yahoo.com/kawhi-leonard-working-on-music-project-will-send-proceeds-to-mamba-and-mambacita-foundation-202633206.html.

40.  FOX Sports Unveils 2021 College Football On-Air Roster, Fox Sports (Aug. 26, 2021), https://www.foxsports.com/presspass/latest-news/2021/08/26/fox-sports-unveils-2021-college-football-air-roster.

41.  Interview with Daniel Hennes (2021) (on file with journal).

42.  Id.

43.  Interview with Marshall Cherrington, supra note 3.

44.  Nellie Andreeva, Overtime Sports Startup Launches College Athlete Creator Studio, Signs NIL Deal With Ceyair Wright, Deadline (Aug. 9, 2021), https://deadline.com/2021/08/overtime-college-athlete-creator-studio-nil-deal-ceyair-wright-1234811859/.

45.  Id.

46.  Claudette Montana Pattison, Caleb Williams Lands Third Massive NIL Deal, Sports Illustrated (Feb. 11, 2022), https://www.si.com/college/usc/football/caleb-williams-third-nil-deal.

47.  Id.

48.  See Fanatics Authentic (@FansAuthentic) Twitter, (Feb. 9, 2022), https://twitter.com/FansAuthentic/status/1491532636837359625?cxt=HHwWksC92fvB._rIpAAAA , Beats by Dre (@beatsbydre) Twitter, (Feb. 4, 2022), https://twitter.com/beatsbydre/status/1489748523616817153?cxt=HHwWgsC-rfSY06wpAAAA.

49.  Claudette Montana Pattison, USC QB Caleb Williams Lands Jaw Dropping NIL Deal, Sports Illustrated (Feb. 17, 2022), https://www.si.com/college/usc/football/caleb-williams-real-estate.

50.  Ryan Kartje, USC Quarterback Kedon Slovis Signs Deal with Klutch Sports, L.A. Times (July 22, 2021), https://www.latimes.com/sports/usc/story/2021-07-22/usc-quarterback-kedon-slovis-signs-deal-with-klutch-sports.

51.  See Kedon Slovis (@kedonslovis), Instagram, (Jul. 23, 2021), www.instagram.com/p/CRr97rjjv1M/.

52.  See Kedon Slovis (@kedonslovis) Instagram, (Aug. 10, 2021), www.instagram.com/p/CSatsFJHG_W/.

53.  See Kedon Slovis (@kedonslovis), Instagram, (Sept. 17, 2021), www.instagram.com/p/CT7YELPIM9L/.

54.  Interview with Daniel Hennes, supra note 41.

55.  See Interview with Spencer Harris, supra note 28.

56.  Id.

57.  USC football and J1s Launch 'Blvd Studios' USC Athletics, USC Athletics (Oct. 29, 2020), https://usctrojans.com/news/2020/10/29/usc-trojans-football-j1s-launch-blvd-studios-name-image-likeness.aspx.

58.  Id.

59.  Interview with Spencer Harris, supra note 28.

60.  See USC Football and J1S Launch ‘BLVD Studios’ USC Athletics, supra note 57.

61.  See Hosick, supra note 2.

62.  Interview with Spencer Harris, supra note 28.

63.  Interview with Daniel Hennes, supra note 41.

64.  Cal. Educ. Code § 67456 (West).

65.  See University of Southern California Athletic Agent Policy, USC Athletics, (Aug. 13, 2018), https://s3.amazonaws.com/sidearm.sites/usctrojans.com/documents/2018/8/13/USC_Athletic_Agent_Policy.pdf.

66.  Interview with Spencer Harris, supra note 28.

67.  USC Athletics Announces Partnership with Altius Sports Partners to Develop Comprehensive NIL Program, USC Athletics (June 18, 2021), https://usctrojans.com/news/2021/6/18/usc-trojans-athletics-altius-sports-partners-name-image-likeness-nil-ncaa.aspx.

68.  See Casey Schwab, LinkedIn, https://www.linkedin.com/in/cdschwab/ (last accessed Nov. 4, 2021).

69.  See Courtney Brunious, LinkedIn, https://www.linkedin.com/in/courtney-brunious-301bb96/ (last accessed Nov. 4, 2021).

70.  See USC Athletics Announces Partnership with Altius Sports Partners to Develop Comprehensive NIL Program, supra note 67.

71.  Interview with Spencer Harris, supra note 28.

72.  Id.

73.  Edelman, supra note 14.

74.  Hosick, supra note 2.

75.  Interview with Kyle Siemer, supra note 20.

76.  Cory Booker Press, Senators Booker and Blumenthal Introduce College Athletics Bill of Rights, Cory Booker (Dec. 17, 2020), https://www.booker.senate.gov/news/press/senators-booker-and-blumenthal-introduce-college-athletes-bill-of-rights.

77.  Sydney Umeri, How Each NIL Bill in Congress Will Affect Student-Athletes, SBNation (June 23, 2021), https://www.sbnation.com/college-basketball/2021/6/23/22545287/college-athletes-name-image-likeness-bills-ncaa.

78.  Id.

79.  Id.

80.  Id.

81.  Interview with Kyle Siemer, supra note 20.

82.  Interview with Marshall Cherrington, supra note 3.

83.  Interview with Kyle Siemer, supra note 20.

84.  Interview with Daniel Hennes, supra note 41.

85.  Sallee, Barrett, USC hires Lincoln Riley from Oklahoma, making major splash in college football coaching carousel, CBS Sports (Nov. 28 2021), https://www.cbssports.com/college-football/news/usc-hires-lincoln-riley-from-oklahoma-making-major-splash-in-college-football-coaching-carousel/.

86.  RJ Young, Caleb Williams to USC Continues ‘Oklahoma West’ Transformation, Fox Sports (Feb. 1, 2022), https://www.foxsports.com/stories/college-football/caleb-williams-to-usc-continues-oklahoma-west-transformation.

87.  USC, Full- Time Assistant Coaching Staff Named by New USC Football Head Coach Lincoln Riley, USC Trojans (Jan. 10, 2022), https://usctrojans.com/news/2022/1/10/assistant-coaching-staff-named-usc-trojans-football-head-coach-lincoln-riley.aspx.

About the writer…