By Martin J. Greenberg and Lori Shaw
According to Forbes Magazine, the average value of a team in the National Football League (NFL) is $1.43 billion for 2015,[1] bringing the NFL’s worth just shy of $46 Billion. In order to stay competitive in this ever-increasing money game that is the NFL, teams are seeking new means to generate revenue from the traditional sources, such as ticket revenues and merchandising, to the unconventional means, such as auctioning off pieces of an old stadium to help pay for a new one. But no money-making technique has been more useful, or more lucrative, than NFL teams selling the naming rights for their stadiums and netting the proceeds therefrom.
Naming rights for NFL stadiums are vitally important to NFL teams. Sometimes they help to pay for the construction of a new stadium, but more often the naming rights proceeds entirely goes, completely and solely, to the NFL team. Under the terms of the most recent Collective Bargaining Agreement (CBA) between the NFL and the NFL Players Association, which went into effect in 2011, revenue generated from naming rights deals are not combined with the other league-wide revenue sources to determine the salary cap or player cost amounts.[2] Specifically concerning naming rights and league-wide revenue distributions, Article 12, Section 1(a)(iii) of the CBA states, “[All Revenue] shall not include naming rights and cornerstone sponsorship proceeds that are dedicated to and used for stadium construction or stadium renovation projects commenced after the date of this Agreement, and that have received a waiver of any applicable League requirement of sharing ‘gross receipts.’”[3] Thus, naming rights deals, when combined with the other revenue teams earn throughout the year, are used to help teams stay competitive both on the field, by being able to afford the best available players, and at the field, by being able to build state-of-the-art stadiums and accommodations.
The most recent stadium naming rights to be sold have followed closely on the heels of new stadiums being built. Recently, the Atlanta Falcons (Falcons) are constructing a new stadium in Atlanta, Georgia and since then have sold the naming rights of their new stadium to Mercedes-Benz (who, coincidentally, also has the stadium naming rights to the Falcon’s NFC-South foe, the New Orleans’ Saints). The details of the agreement between the Falcons and Mercedes-Benz have not yet been released. However, the Mercedes-Benz-New Orleans Saint’s deal is reportedly worth somewhere between $50–$60 million dollars and extends for ten years through the 2021 season.[4]
Under the terms of the lease agreement for the New Orleans’ Mercedes-Benz Superdome, the Saints have the authority to negotiate a naming rights deal for the state-owned stadium Superdome.[5] However, the Saints receive the first $1 million from Mercedes-Benz and the remaining amount paid by Mercedes-Benz is split 50-50 between the Saints and State of Louisiana, which is applied to offset the State’s remaining subsidy payments for the Superdome.[6] Unlike New Orleans’, the Falcons, or the Atlanta Falcons Stadium Company, LLC (StadCo), not only have the ability to negotiate a naming rights deal for the new Falcons’ stadium, but the Falcons’ also retain all of the revenue from any naming rights agreement under the terms of the stadium lease agreement. The Falcons’ lease agreement states,
StadCo will have the right to select the name or names of the [New Stadium Project (NSP)], as well as the sponsor or sponsors for which the various portions of the NSP will be named from time to time, and StadCo will additionally have the right to select and will be responsible for all signage, branding, sponsorship or other similar rights with respect to the NSP… [and ] to retain all proceeds therefrom.[7]
So, not only do the Falcons retain all revenue from their stadium naming rights agreement, they are also not subject to the approval of the state, city, or county as long as the signage or sponsorship does not violate any term or condition of the stadium lease agreement (i.e. the Naming Rights cannot go to a company that would embarrass any party to the agreement or be offensive to the general public).[8]
Another stadium also gained a new name to perch atop its entrance. The Tennessee Titans (Titans) reached a naming rights agreement with Nissan North American, a car manufacturer with its North American headquarters just south of Nashville in Franklin, Tennessee with another large manufacturing plant in Smyrna, Tennessee, on June 24, 2015. The stadium in Nashville, Tennessee will now be called “Nissan Stadium.”[9] In addition to placing the Nissan name on the stadium, Nissan will also place a Nissan pickup truck next to the scoreboard. The agreement reached between the Titans and Nissan includes a 20-year term,[10] although the financial details of the deal have not been released.
Finally, after playing at the University of Minnesota’s stadium for the 2014 and 2015 seasons, the Minnesota Vikings (Vikings) have a stadium to call their own: “U.S. Bank Stadium.”[11] The Vikings and U.S. Bank have reached a 20-year agreement reportedly worth $220 million.[12] The Vikings agreement with U.S. Bank is also reportedly closely identical to the San Francisco 49ers agreement with Levi Strauss & Co.[13] If this is true, this would make the 49ers and the Vikings tied for the third highest NFL stadium naming rights contracts with the NFL behind only the New York Giants/New York Jets’ $16 million per year agreement with MetLife Insurance[14] and the Dallas’ Cowboys reported $17–$19 million per year contract with AT&T[15] (although there are reports that both deals are worth upwards of $17 million per year).[16] The top five NFL stadium naming rights contracts is rounded out by the Houston Texans’ Reliant Stadium at $10 million per year and the New England’s Gillette Stadium at $ 8 million per year.[17] Like the Falcons, under the terms of the Viking’s stadium lease, the Vikings “shall have the exclusive right to contract for and receive all revenue from . . . the grant, licensing, and sublicensing of any and all Naming Rights.”[18] Additionally, under the terms of the lease, the Vikings can have two Naming Rights partners: (1) one for the Stadium and (2) one for the Plaza located next to the stadium.[19]
Although naming rights agreements usually follow the construction, or at least the ground breaking, of new stadiums, historical franchises in the NFL, not quite ready to give up their historic monikers, also garner some weight in attracting potential naming rights counterparts. For example, the Chicago Bears have entered into their first naming rights agreement with PNC Bank, not for the stadium name, but for the Soldier Field suites and the Bear’s Halas Hall.[20] The agreement also designates PNC as the official, and exclusive, banking partner of the Chicago Bears.[21] Although the logistics of the deal have not been reported yet, the PNC-Bears partnership is most likely close to ten years and estimated to be worth somewhere between $25-$35 million.[22]
Some college football programs are also looking for ways to capitalize on the success, or notoriety, of their football programs, but are not giving up the names to their stadiums just yet. The University of California (Cal) recently sold the naming rights to their field to Kabam, but did not sell the name to Cal Memorial Stadium.[23] The agreement between Cal and Kabam is worth $18 million over 15 years.[24]
This begs the question, however: As the NFL’s smallest market team, how have the Green Bay Packers (Packers) been able to stay consistently competitive despite not selling the naming rights to historic Lambeau Field?
After facing pressure from the NFL to update Lambeau Field, a referendum was held in September 2000 to determine whether Brown County residents would take on a share of the construction costs to update Lambeau Field with a .5% sales tax.[25] The referendum was passed by the residents of Brown County on September 12, 2000 with a vote of 53% in favor to 47% against.[26] But, many residents and Mayor Paul Jadin were still looking for ways to help reduce the burden on the residents of Brown County, so Mayor Jadin strongly advocated that the Packers sell the naming rights to Lambeau Field as a way to offset the amount of money, and time for which Brown County residents would have to pay.[27] A second referendum was held two months after Brown County residents approved the .5% sales tax to determine whether Brown County residents favored selling naming rights to Lambeau Field in order to offset the construction costs.[28] The second referendum, like the first, was approved by a 53% vote in favor of selling naming rights to Lambeau Field to 47% against.[29] Under an agreement between the City of Green Bay and the Packers, both parties would have to agree to the selling of the naming rights in order for any agreement to be negotiated and accepted.[30] If a naming rights agreement were to be accepted, though, the Packers and the City of Green Bay would share equally in the revenue (pursuant to the stadium legislation), substantially reducing the amount owed by taxpayers to renovate the stadium.[31] However, it was publicly noted that the Packers and the City would not sell naming rights to Lambeau Field unless they received at least $100 million dollars.[32] The Packers were looking to naming rights of the stadium as a last resort.[33] Former Packers’ President and CEO, Robert Harlan, was outspoken during this process against selling the naming rights for Lambeau Field. “We have fought to save Lambeau, and we will fight to save the tradition of Lambeau Field,”[34] said Harlan, but he acknowledged that “the citizens of the county voted to sell naming rights, and we owe it to [the] citizens to go through the process.”[35] On the other hand, Harlan noted that he felt that Brown County residents had “vot[ed] their pocketbooks against tradition,”[36] suggesting that the $295 price tag loomed ever-present in voters minds during the referendum.[37] Had the referendum been taken at a later time, Harlan suggested that the residents “would [have gone] to the polls with a different mindset.”[38]
In order to remain competitive in the NFL and offset some of the burden on Brown County residents, the Packers looked to alternative sources of revenue in order to ease this burden. In response, the Packers, instead of selling naming rights to Lambeau Field, sold naming rights to the various gate entrances at Lambeau Field. Long-time sponsors of the Packers, Miller Brewing and the Oneida Nation were among the first to sponsor a gate at Lambeau Field in 2003.[39] Following their commitment, Verizon Wireless, Associated Bank, and Fleet Farms also joined in and sponsored their own gates.[40] Originally, there were only five sponsored gates at Lambeau Field. Today, after the second round of renovations at Lambeau Field, there are eight sponsored gates including Miller Brewing, Oneida Nation, Verizon Wireless, Associated Bank, Fleet Farms, American Family Insurance, Bellin Health, and Shopko.[41]
The original gate sponsorship agreements all included a ten year sponsorship period, except Verizon Wireless, which only extended for a seven year period.[42] The initial Packers-Miller Brewing (now MillerCoors) gate sponsorship agreement extended for ten years, from 2002-2012 and, although no financials have been disclosed, it is reported that the deal was worth upwards of $2 million per year, making it the highest price-tag associated with a gate at Lambeau Field.[43] The MillerCoors gate entrance is the Titletown Atrium, which is the stadiums main entrance.[44] The Packers and MillerCoors have since extended their gate sponsorship agreement through the 2022 season.[45] With the second largest gate at Lambeau Field, Onieda Nation also reportedly has the second largest price-tag associated with gate sponsorship, although financials of the original ten year agreement have also not been released.[46] The Packers and Oneida Nation, like MillerCoors, have also extended their sponsorship agreement with the Packers for an additional ten years running through the 2022 season.[47] The Oneida gate is the second largest gate at Lambeau Field and faces the main parking lot.[48] Associated Bank’s initial ten year sponsorship included the premium-seat gate located on Ridge Road, which is the entrance for private box/suite holders and club seats.[49] Fleet Farms has also renewed its original ten year deal through the 2022 season, continuing to sponsor the southwest gate entrance.[50] Verizon Wireless, which had the shortest gate sponsorship deal of the original five, extended their partnership with the Packers through the 2013 season,[51] and again for a multi-year period. The Verizon Wireless gate is also located on Ridge Road near Lombardi Avenue.[52]
The Packers extended their gate sponsorships in 2012 with the additions of three new gates at Lambeau Field as part of the most recent renovations to the stadium. The first gate to be claimed was the new south end gate. Shopko, a Wisconsin retailer, entered into a multi-year agreement, which expanded on their previous twenty year relationship as a sponsor of the Green Bay Packers.[53] Bellin Health was the next to sign on to sponsor one of the newly renovated gates at Lambeau Field. The Bellin Health gate is located at the north side of the stadium.[54] The last gate to be acquired went to American Family insurance. The Packers-American Family Insurance sponsorship will run through the 2023 season and the American Family Insurance gate will be located at the new east side entrance.[55]
Years after the initial proposition to begin discussions regarding selling the naming rights to Lambeau Filed, President Murphy continues to be a strong supporter of leaving the name Lambeau Field untouched atop the Packers stadium. Murphy stated that “[The Packers] have a number of benefits as an organization, b[b]ut Lambeau Field is right near the top. It would really be a shame if the name was ever changed.”[56] Although President Murphy has been approached over the years from interested companies hoping to put their name and logo on top of Lambeau Filed, Murphy replies with “thanks, but no thanks. We have no interst.”[57] Thus, the Packers have continued to sell naming rights for the various gate locations throughout Lambeau Field, but will leave the iconic Lambeau Field alone forever, according to President Murphy.[58]
While the exact financial details that the Packers have received from gate sponsorships have not been released, it is safe to assume that the Packers have come up with a creative way to remain competitive in the NFL without giving up the historic moniker that dons the top of Green Bay’s stadium. Actually, the Packers may have one of the best, or at least most innovative, strategies in the NFL when it comes to selling stadium naming rights. Instead of one entity paying, for example, $8 million every year to have their name on a stadium, the Packers have 8 entities with their names not only above a specific gate, but also throughout the stadium, each paying assumingly somewhere between $1 and $3 million per year, resulting in essentially what they would receive for one naming rights deal.[59] While the Packers may not be the richest team in the NFL, the fact that they haven’t bought into the idea of selling the naming rights to gain more revenue has not pushed them too far down the list of top grossing NFL teams. In actuality, the Packers are the 10th most valuable franchise in the NFL at $1.95 billion.[60] Last year, the Packers collected $375.7 million in revenues, which jumped $50 million from the previous year and is a 15% jump from the previous year.[61] This increase in revenue is due to a $38.7 million increase in revenue from broadcasting agreements and from a $12.9 million increase from local revenues from the new Packers Pro Shop.[62] Not only did the Packers generate a record setting revenue number, but the Packers had a $29.2 million net income and an operating profit of $39.4 million, which is another 15% increase from the previous year.[63] President Murphy has stated that he doesn’t “think it makes any sense” to sell the naming right to Lambeau Field,[64] and the financials from last year support this statement. It appears evident that the Packers will be able to keep up financially with the rest of the league, even surpassing some teams with naming rights agreements. And, while naming rights may have been figuratively on the table a decade ago, Packers President Mark Murphy shares in his predecessors opposition to attaching a corporate name to Lambeau Field. Murphy has made clear that 2000 was the last, and only, time naming rights to Lambeau Field would be discussed. “We will not sell the naming rights to [Lambeau Field]…We will never do that…It will always be Lambeau Field.”[65]
Lori Shaw is currently a 3L at Marquette University Law School where she is focusing on Intellectual Property and Sports Law. Shaw is the Managing Editor for the Marquette Intellectual Property Law Review, a member of the Marquette Sports Law Review, and a Sports Law Certificate candidate for May 2016. Shaw is also a member of the Employment Law Society and Sports Law Society. Prior to coming to Marquette Law, Shaw double-majored in History and Political Science, with a Psychology minor, at Indiana University in Bloomington, Indiana.
[1] Mike Ozanian, The NFL’s Most Valuable Teams, Forbes (Aug. 20, 2014), http://www.forbes.com/sites/mikeozanian/2014/08/20/the-nfls-most-valuable-teams/.
[2] Mike Ozanian, Value of Cowboys Up $100 Million from Stadium Naming Rights Deal, Forbes (July 26, 2013), http://www.forbes.com/sites/mikeozanian/2013/07/26/value-of-cowboys-up-100-million-from-stadium-naming-rights-deal/; however, under the terms of the most recent CBA, a small percentage of the naming rights deals goes to the players.
[3] National Football League- National Football League Players Association Collective Bargaining Agreement, art. 12, § 1(a)(iii).
[4] Mercedes-Benz, Saints Reach 10-year Naming-Rights Agreement for Superdome, Sports Business Daily (Oct. 4, 2011), http://www.sportsbusinessdaily.com/Daily/Issues/2011/10/05/Facilities/Superdome.aspx.
[5] Nakia Hogan, New Orleans Saints Sell Superdome Naming Rights to Mercedes-Bens, NOLA.com (Oct. 3, 2011), http://www.nola.com/saints/index.ssf/2011/10/new_orleans_saints_sells_super.html.
[6] Id.
[7] Georgia World Congress Center Authority- The Atlanta Development Authority et. al., Transaction Agreement (Feb. 5, 2014), available at http://www.gwcc.com/about/stadium/reports/NSP%20-%20Transaction%20Agreement%20(EXECUTION).pdf.
[8] Id.
[9] Curtis Crabtree, Report: Nissan reaches naming rights deal for Titans Stadium, NBC Sports (June 24, 2015), http://profootballtalk.nbcsports.com/2015/06/24/report-nissan-reaches-naming-rights-deal-for-titans-stadium/.
[10] Id.
[11] Hubert H. Humphrey Metrodome, Wikipedia, https://en.wikipedia.org/wiki/Hubert_H._Humphrey_Metrodome (last modified Sept. 30, 2015).
[12] Rochelle Olson, New Vikings Stadium will be Named for U.S. Bank, STAR TRIBUNE (June 16, 2015), http://www.startribune.com/report-us-bank-vikings-sign-naming-rights-deal-worth-9-million-annually-to-the-team/307444581/.
[13] Id.
[14] Louis Bien, 49ers’ Levi’s Stadium the 3rd-biggest Naming Rights Deal in American Sports, SBNation (May 8, 2013), http://www.sbnation.com/nfl/2013/5/8/4313344/49ers-levis-stadium-biggest-naming-rights-contracts.
[15] Staff Reports, Report: AT&T Naming Rights for Dallas Cowboys’ Stadium $17-19M a Year, Dallas News (July 25, 2013), http://www.dallasnews.com/sports/dallas-cowboys/headlines/20130725-dallas-cowboys-announce-major-business-related-press-conference-today.ece.
[16] Nancy Badertscher, Mercedes-Benz on Target with Superlative about Atlanta Stadium Rights, PolitiFact Geogra (Aug. 27, 2015), http://www.politifact.com/georgia/statements/2015/aug/27/steve-cannon/mercedes-benz-target-superlative-about-atlanta-sta/.
[17] Louis Bien, supra note 18.
[18] Minnesota Sports Facilities Authority-Minnesota Vikings Football, LLC, Stadium Use Agreement, art. 11, § 11.1(c) (Oct. 3, 2013).
[19] Id. at art. 11, § 11.1(a)
[20] Becky Yerak, Chicago Bears Strike Naming-Rights, Banking Deal with PNC, THE CHICAGO TRIBUNE (April 21, 2015), http://www.chicagotribune.com/business/ct-bears-pnc-sponsorship-0422-biz-20150421-story.html.
[21] Id.
[22] Id.
[23] Alicia de Artola, LA Coliseum Naming Rights Are Uncharted Waters in College Football, Fansided (July 17, 2015), http://reignoftroy.com/2015/07/17/la-coliseum-naming-rights-are-uncharted-waters-in-college-football/.
[24] Id.
[25] Editorial: Lambeau Naming-rights Climate Cools, Packers News (Dec. 11, 2001), http://159.54.235.74/legacy/lambeau/archive/pack_1741508.shtml.
[26] Talks to Open over Naming Rights to Lambeau Field, ESPN (June 19, 2003), http://a.espncdn.com/nfl/news/2003/0619/1570576.html; Jeff Mayers, Stadium Facelift Roils Wisconsin Politics, Stateline (Nov. 20, 2000), http://www.pewtrusts.org/en/research-and-analysis/blogs/stateline/2000/11/20/stadium-facelift-roils-wisconsin-politics; Lambeau Field, Wikipedia, https://en.wikipedia.org/wiki/Lambeau_Field (last modified Oct. 3, 2015).
[27] AP, Naming Rights Proposal on Lambeau Field Presented by Mayor, The Journal Times (June 21, 2000), http://journaltimes.com/naming-rights-proposal-on-lambeau-field-presented-by-mayor/article_377e2f89-7bd3-547c-a7f1-02e3a5da0b5f.html.
[28] Mayers, supra note 30; Talks to Open over Naming Rights to Lambeau Field, supra note 30.
[29] Id.
[30] Naming Rights Proposal on Lambeau Field Presented by Mayor, supra note 31.
[31] Talks to Open over Naming Rights to Lambeau Field, supra note 30.
[32] Id.
[33] John Lombardo, Packers Resist Call for Naming-Rights Sale, Sports Business Daily (June 26, 2000), http://m.sportsbusinessdaily.com/Journal/Issues/2000/06/20000626/No-Topic-Name/Packers-Resist-Call-For-Naming-Rights-Sale.aspx.
[34] Id.
[35] Talks to Open over Naming Rights to Lambeau Field, supra note 30.
[36] Mayers, supra note 30.
[37] Editorial: Lambeau Naming-rights Climate Cools, supra note 29.
[38] Id.
[39] Todd Korth, Another Gate Locked up at Lambeau, PackerReport (Mar. 12, 2003), http://www.scout.com/nfl/packers/story/98810-another-gate-locked-up-at-lambeau.
[40] Id.
[41] Corporate Partners, Packers.com, http://www.packers.com/fan-zone/corporate-partners.html (last visited Oct. 3, 2015).
[42] Verizon to be Gate Sponsor at Lambeau Field, Milwaukee Business Journal (Aug. 14, 2002), http://www.bizjournals.com/milwaukee/stories/2002/08/12/daily29.html.
[43] Korth, supra note 44.
[44] Todd Korth, Miller Named as Major Gate Sponsor, Packer Report (July 22, 2002), http://www.scout.com/nfl/packers/story/54841-miller-named-as-major-gate-sponsor.
[45] Cary Docter, Packers, MillerCoors Extend Partnership with Ten-Year Deal, Fox6Now (July 17, 2002), http://fox6now.com/2012/07/17/packers-millercoors-extend-partnership-with-ten-year-deal/.
[46] Langdon Brockinton, Oneida Nation Becomes Packers Sponsor, Sports Business Journal (Aug. 5, 2002), http://m.sportsbusinessdaily.com/Journal/Issues/2002/08/20020805/This-Weeks-Issue/Oneida-Nation-Becomes-Packers-Sponsor.aspx; Korth, supra note 44.
[47] Oneida Renews Sponsorship of Green Bay Packers, Milwaukee Business Journal (Oct. 29, 2012), http://www.bizjournals.com/milwaukee/news/2012/10/29/oneida-renews-sponsorship-of-green-bay.html.
[48] Korth, supra note 44.
[49] Associated Expands Sponsorship of Packers, Milwaukee Business Journal (Mar. 14, 2003), http://www.bizjournals.com/milwaukee/stories/2003/03/10/daily37.html.
[50] Packers, Mills Fleet Farm Renew Decade-Long Partnership, Packers.com (Mar. 16, 2012), http://www.packers.com/news-and-events/article-1/Packers-Mills-Fleet-Farm-renew-decade-long-partnership/e5e38885-6d34-4ed3-b3c4-caa9626b56ee.
[51] Don Walker, Packers, Verizon Extend Agreement, Milwaukee Journal Sentinel (Aug. 24, 2009), http://www.jsonline.com/blogs/sports/54589837.html.
[52] Verizon to be Gate Sponsor at Lambeau Field, supra note 47.
[53] Packers, Shopko Partner for Lambeau Filed South End Gate, Packers.com (July 23, 2012), http://www.packers.com/news-and-events/article-1/Packers-Shopko-partner-for-new-Lambeau-Field-South-End-Gate/d47db293-2b0d-4792-bc77-33a435f89f60.
[54] Packers, Bellin Health Expand Partnership, Packers.com (July 30, 2012), http://www.packers.com/news-and-events/article-1/Packers-Bellin-Health-expand-partnership/b8c2f02d-0757-40c1-b6ed-38fa41fb86f7.
[55] Packers, American Family Insurance Renew Partnership for 10 Years, Packers.com (July 15, 2014), http://www.packers.com/news-and-events/article-press-release/article-1/Packers-American-Family-Insurance-renew-partnership-for-10-years/8e9752cd-28b3-4126-94fb-e6a4bb25368a.
[56] Jason Hirschhorn, Mark Murphy Says Packers Will ‘Never’ Sell Naming Rights to Lambeau Field, Acme Packing Co. (July 29, 2015), http://www.acmepackingcompany.com/2015/7/29/9064573/lambeau-field-packers-naming-rights-mark-murphy-shareholders-meeting.
[57] Rob Demovsky, Packers Presdient: ‘No Interest’ In Selling Lambeau Naming Rights, ESPN (July 28, 2015), http://espn.go.com/nfl/story/_/id/13332177/packers-president-mark-murphy-says-there-no-interest-selling-lambeau-field-naming-rights.
[58] Id.
[59] See e.g., Katie Delong, Packers unveil second sponsored gate at Lambeau Field, Fox6Now (July 30, 2012), http://fox6now.com/2012/07/30/packers-unveil-second-sponsored-gate-at-lambeau-field/.
[60] NFL Team Values 2015, Forbes, http://www.forbes.com/pictures/mlm45fljdi/10-green-bay-packers/; Mike Ozanian, The Most Valuable Teams in the NFL, Forbes (Sept. 14, 2015), http://www.forbes.com/sites/mikeozanian/2015/09/14/the-most-valuable-teams-in-the-nfl/.
[61] Mike Spofford, New Broadcast Contracts, Pro Shop Contribute to Another Revenue Record, Packers.com (July 20, 2015), http://www.packers.com/news-and-events/article-1/Packers-financial-picture-remains-strong/5b23fe6d-0df4-4440-9c94-cbc4f9119146.
[62] Id.
[63] Id.
[64] Genaro Armas, Packers President: Naming Rights Off Limits for Lambeau, AP The Big Story (July 28, 2015), http://bigstory.ap.org/article/bb2cf2bcb41a4adabe9d3259be0f0c4c/packers-president-naming-rights-limits-lambeau.
[65] Packers President Says Naming Rights Off Limits for Lambeau Field, Fox Sports (July 28, 2015), http://www.foxsports.com/wisconsin/story/green-bay-packers-president-mark-murphy-says-naming-rights-off-limits-for-lambeau-field-072815.