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  #541  
Old Posted May 21, 2009, 10:31 AM
bornagainbiking bornagainbiking is offline
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Money talks

Good point. If the Coyotes stand to lose so much money and the NHL want so much say, Call their bluff. Mr. Basille should simply put his offer on the table and walk away.
Tell them, Call me when you are serious or come to your senses.
Hockey is about the fans and I think the Board of Govenors is too full of themselves.
When you are reporting millions of dollars in losses, it is no time to wrestle for power or be so protective. Survival of the market not a false or proped market.
There is a Canadian market when Jr A teams pack over 4000 nightly in cities of 80000 on a week night. For Copps they want the corporate boxes why not just more reasonably priced seats for the common folk.
Give hockey back to the people the fans.

Last edited by bornagainbiking; May 21, 2009 at 10:32 AM. Reason: typo
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  #542  
Old Posted May 21, 2009, 2:30 PM
drpgq drpgq is offline
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Balsillie believes bold bid will win

Play for Coyotes bolstered after first court date

Bruce Arthur, National Post Published: Thursday, May 21, 2009

Say what you will about Jim Balsillie -- and Gary Bettman certainly would, away from the microphones -- but the man believes. The man believes that he can take on the four biggest sports leagues in North America. He believes that he can bash his way into what is usually a very particular club. He believes, despite armies of lawyers and plenty of obstacles, that he will win.

And the co-chairman of Research In Motion, the Blackberry billionaire, believes all the more following the first of many court showdowns over the fate of the Phoenix Coyotes in an Arizona courtroom Tuesday. There were a lot of conflicting interpretations of those opening dance steps, which resulted in two things: an order of mediation between alleged Coyotes owner Jerry Moyes and the NHL, both of whom claim they are in charge of the team; and a scheduled hearing over whether the team can be sold as a portable item.

The first of those appears to be largely irrelevant -- a matter of covering bases rather than searching for a home run. The second one has Balsillie, in his first public comments about Tuesday's proceedings, over the moon.

"Yesterday couldn't have gone any better," said Balsillie in an interview on The Fan 590 and Sportsnet, to which this reporter was a party along with host Bob McCown. "Yesterday was a really, really good day. We had something that was considered an impossibility by many people, which has now got momentum and is on the verge of happening. This is on the verge of happening, and it's court supervised."

To say that the day could not have gone any better seems to be a bit of a stretch. Balsillie, of course, is trying to buy the team out of bankruptcy (a bankruptcy which the National Hockey League is contesting) in order to relocate them to Hamilton (a right which the National Hockey League is contesting). He is trying to force his way into the NHL using their own rules, and also the law.

If Judge Redfield T. Baum had ruled right away that Moyes had the right to declare bankruptcy and sell the club, then agreed to the move-it-hurry-let's-go timelines proposed by the Moyes and Balsillie people, and essentially started the moving trucks towards southern Ontario, then it could not have gone any better for Balsillie. That, plus maybe awarding the team Sidney Crosby. That would have been pretty good.

But Balsillie believes that the scenario he has audaciously put forward-- that by using the NHL's own constitution against its commissioner, the Canadian billionaire finally finds the door into the league he wants so badly to join--is in play.

"What was most important yesterday was that the judge is going to rule on relocation," Balsillie said, referring to the scheduled hearing on June 22. "Like they said, it's for our courts to decide. That's a key issue.

"The important one is that there's going be an auction and they're going decide on location before that auction and a court is going to decide. And that is a really, really positive development."

The basic tenet of Balsillie's argument is this: At its core, this case comes down to whether the bankruptcy judge rules for the creditors or the leagues. If Baum decides that the most critical issue is the protection of the rights of the many creditors in this case -- which is usually what bankruptcy judges are charged with doing -- then the bankruptcy auction can go forward, with Balsillie in the lead. Because if Baum decides the creditors are paramount, then he could rule that relocation is the best way to protect said creditors.

So instead of the NHL deciding who gets to own what team, and who gets to move which team where, the judge could decide bankruptcy trumps that right.

If, on the other hand, the judge is leery of the precedent such a ruling would make -- potentially roiling not just hockey but the NBA, NFL and Major League Baseball, all of whom stand in support of their fellow sports monopoly -- and decides that overrides the interests of the creditors, then Balsillie would lose. And unless he has mortally wounded Bettman, or is willing to try another judge and another team, Balsillie might never get another kick at the can.

But right now, the man from Waterloo believes he is close to pulling off this magic trick. Is it an illusion? Maybe. But between the first day in court, and the public relations coup he has pulled off in mobilizing public support on this issue -- with more than 125,000 people signed up for the movement's Web site, makeitseven.ca, and politicians falling over one another to get on board -- he believes.

"You could very clearly characterize this as being on the verge of happening," Balsillie said. "Yesterday was a very good day. Any way you cut it, yesterday was a very good day.

"Hockey Nation in Canada has spoken.

"Am I optimistic? Yeah. It's almost unstoppable if we all hang together here. If we all stick together, it's almost unstoppable."
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  #543  
Old Posted May 21, 2009, 3:52 PM
mic67 mic67 is offline
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http://hamilton.en.craigslist.ca/rnr/1181769377.html

"hamilton craigslist > rants & raves


Hey jim baldsilly (relocate some jobs)
Reply to:pers-abt9x-1181769377@craigslist.org [Errors when replying to ads?]
Date: 2009-05-21, 10:16AM EDT


How about relocating some of those blackberry jobs from Malaysia and china to hamilton EH buddy!

No wonder he has billions

Location: relocate some jobs
it's NOT ok to contact this poster with services or other commercial interests


PostingID: 1181769377"

Humm...good idea why hasnt the media called him on that? Hey Hebscher wheres the rant now?? Michael Moore would.

The only reason for him wanting a team and in Hamilton is business and money and absolutely no other reason, that is not a bad reason. He'll pay around $200 million when the real value of the time in southern Ont. will be closer to $400 million. Such a real estate market does not exist in Canada, yet.
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  #544  
Old Posted May 21, 2009, 9:40 PM
Actonite Actonite is offline
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Quote:
Originally Posted by mic67 View Post
http://hamilton.en.craigslist.ca/rnr/1181769377.html

"hamilton craigslist > rants & raves


Hey jim baldsilly (relocate some jobs)
Reply to:pers-abt9x-1181769377@craigslist.org [Errors when replying to ads?]
Date: 2009-05-21, 10:16AM EDT


How about relocating some of those blackberry jobs from Malaysia and china to hamilton EH buddy!

No wonder he has billions

Location: relocate some jobs
it's NOT ok to contact this poster with services or other commercial interests


PostingID: 1181769377"

Humm...good idea why hasnt the media called him on that? Hey Hebscher wheres the rant now?? Michael Moore would.

The only reason for him wanting a team and in Hamilton is business and money and absolutely no other reason, that is not a bad reason. He'll pay around $200 million when the real value of the time in southern Ont. will be closer to $400 million. Such a real estate market does not exist in Canada, yet.
RIM employs thousands in Canada. They are one of the largest employers in Waterloo Region. They provide benefits to all their employees globally. Their product is sold world wide so it only makes sense to have employees world wide.
RIM's two co-CEO's have invested 100's of millions of dollars in Waterloo Region and 10's of millions in other areas of the province.
The investments they have made have helped put Canada on the cutting edge of technology and physics. They are all so bringing innovation to the way we look at governance world wide at CIGI.
Balsillie will make money in Hamilton but Hamilton stands to benefit 10 fold from Balsillie's investment in the NHL.
If there is any one you want involved in your city it is Jim Balsillie and his partner Mike Lazirdas.
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  #545  
Old Posted May 22, 2009, 1:24 AM
BCTed BCTed is offline
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Quote:
Originally Posted by mic67 View Post

The only reason for him wanting a team and in Hamilton is business and money and absolutely no other reason, that is not a bad reason. He'll pay around $200 million when the real value of the time in southern Ont. will be closer to $400 million. Such a real estate market does not exist in Canada, yet.
I have a bit of difficulty believing that Jim Balsillie has been in such hot pursuit of a team because he is trying to make money. I am not sure that a hockey team in Hamilton would be the most efficient way to invest his money. How do you arrive at the $400 MM valuation?
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  #546  
Old Posted May 22, 2009, 1:42 AM
mic67 mic67 is offline
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From a media interview with humm...???, think it was on the Donna and Heb show - chch. the $400 mil. was given as a figure for a NEW nhl club in hamilton and the proceeds of which would go to the existing nhl clubs or the nhl entity. This was one of the spec. reasons why Betts and nhl didnt want to move the team - sounds reasonable and I - believe to be reasonably true.

One reason for BAs. to have a Ham. team was his legacy, what bull shit, if he wanted one, move all the rim jobs to Ham. Its an business thing, ego thing - period. Will it be good for Ham. yes, am I for it? yes. But keep it real. The nhl response to this issue is bull shit - again a monetary decision and ego. NHL in Ham. is good for both the nhl and ham. but most of all hockey itself < that is the point that everyone is missing or willing to over look. I am not an avid hockey fan, I am Canadian...

BTW I actually work on Molson Canadian Commercials with a guy named Bruce Dowad, the true creative -genius- behind their TV spots for many years.

mic67
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  #547  
Old Posted May 22, 2009, 2:42 AM
bigguy1231 bigguy1231 is offline
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Originally Posted by BCTed View Post
I have a bit of difficulty believing that Jim Balsillie has been in such hot pursuit of a team because he is trying to make money. I am not sure that a hockey team in Hamilton would be the most efficient way to invest his money. How do you arrive at the $400 MM valuation?
I don't think he is looking to make alot of money. He just loves the game and wants to be a part of it.

As for the 400 million valuation thats what the experts or so called experts have been throwing around. They figure this area is a gold mine for the NHL. Any potential owner may have to payoff the Leafs and Sabres as well, which could add anywhere from 200-400 million to the cost a new franchise. So if he can get the Coyotes for 200 million and move them it would be a bargain.
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  #548  
Old Posted May 22, 2009, 9:27 AM
drpgq drpgq is offline
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From the National Post

Arguing that a National Hockey League team in Hamilton would be “crippling” for their Buffalo Sabres, two U.S. senators from New York have written commissioner Gary Bettman in opposition of any plan that would see the Phoenix Coyotes relocate to Southern Ontario.

Charles Schumer and Kirsten Gillibrand are worried the competition would weaken the team’s fan base, since the Sabres “receive approximately 15% to 20% of their revenue from the fans that live between Hamilton.”

“The Buffalo Sabres are synonymous with Western New York,” Sen. Gillibrand said in a release posted at NHL.com on Thursday. “The Sabres are crucial to Western New York’s way of life. I am committed to working with Senator Schumer to do everything we can to keep the Sabres successful right here in Buffalo.”

Canadian billionaire Jim Balsillie has offered to buy the Coyotes for US$212.5-million, but has been met with stiff resistance from the NHL. Earlier this week, a bankruptcy court judge in Arizona ordered the NHL into mediation with Coyotes owner Jerry Moyes, and scheduled more oral arguments for June 22.
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  #549  
Old Posted May 22, 2009, 10:21 AM
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Isn't that great?

Southern Ontario is a true hockey market which is under supplied, yet we're denied another team and Buffalo gets protected even though we're keeping them alive. Amazing.

With a team in Hamilton they'll have a good chance at remaining alive - piss us off and we'll stop supporting Buffalo altogether and they'll lose their team anyways.

I wish everyone would just stop supporting the Sabres. Let them make it on their own.
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  #550  
Old Posted May 22, 2009, 12:57 PM
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Please don't tell me the Americans are afraid of a little competition. I always thought the free market was one of the things their society holds dear. lol.
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  #551  
Old Posted May 22, 2009, 7:37 PM
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  #552  
Old Posted May 22, 2009, 8:15 PM
Actonite Actonite is offline
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Quote:
Originally Posted by mic67 View Post
From a media interview with humm...???, think it was on the Donna and Heb show - chch. the $400 mil. was given as a figure for a NEW nhl club in hamilton and the proceeds of which would go to the existing nhl clubs or the nhl entity. This was one of the spec. reasons why Betts and nhl didnt want to move the team - sounds reasonable and I - believe to be reasonably true.

One reason for BAs. to have a Ham. team was his legacy, what bull shit, if he wanted one, move all the rim jobs to Ham. Its an business thing, ego thing - period. Will it be good for Ham. yes, am I for it? yes. But keep it real. The nhl response to this issue is bull shit - again a monetary decision and ego. NHL in Ham. is good for both the nhl and ham. but most of all hockey itself < that is the point that everyone is missing or willing to over look. I am not an avid hockey fan, I am Canadian...

BTW I actually work on Molson Canadian Commercials with a guy named Bruce Dowad, the true creative -genius- behind their TV spots for many years.

mic67
In the Waterloo Record today it was announced that the greedy Mr. Balsillie and his partner Mr.Lazaridas have donated an other 347,000,000 dollars to organizations in Waterloo Region.
This guy is all about him self!
I know it's not money being spent in Hamilton but the point is Jim Balsillie may well want a hockey team for him self and maybe it's even an ego thing but he is a very generous man.
Take it from some one who lives in the same city as Mr.Balsillie and has seen how much this guy really cares about the city he lives in, the province and the entire country. If Jim says he's doing this for the hockey fans(there are millions of us)of southern Ontario, he means it. What ever he does for you in Hamilton it will be well worth it.
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  #553  
Old Posted May 23, 2009, 12:50 AM
crhayes crhayes is offline
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Originally Posted by Actonite View Post
In the Waterloo Record today it was announced that the greedy Mr. Balsillie and his partner Mr.Lazaridas have donated an other 347,000,000 dollars to organizations in Waterloo Region.
This guy is all about him self!
I know it's not money being spent in Hamilton but the point is Jim Balsillie may well want a hockey team for him self and maybe it's even an ego thing but he is a very generous man.
Take it from some one who lives in the same city as Mr.Balsillie and has seen how much this guy really cares about the city he lives in, the province and the entire country. If Jim says he's doing this for the hockey fans(there are millions of us)of southern Ontario, he means it. What ever he does for you in Hamilton it will be well worth it.
This is why I am a CrackBerry addict for life!!
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  #554  
Old Posted May 23, 2009, 4:51 PM
mic67 mic67 is offline
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http://www.thespec.com/News/Local/article/570842

What would it be worth?


Study says a team in Hamilton could reach $600m in market value
May 23, 2009
Joan Walters
The Hamilton Spectator
(May 23, 2009)

"Balsillie's acquisition of the Coyotes for $212.5 million US could be an especially shrewd investment."

"Hockey-mad Canadians might remedy the problem.

Last year, an NHL report on ticket revenues for its 30 teams showed the six Canadian franchises account for almost a third of the $1.1 billion US in ticket revenue."

"Team values

1 Toronto Maple Leafs 448" etc, etc
---------------------------

"In the Waterloo Record today it was announced that the greedy Mr. Balsillie and his partner Mr.Lazaridas have donated an other 347,000,000 dollars to organizations in Waterloo Region."

Link please?
-----------------------------

Keep it real.

"There is big business is Disneyland".

mic67

"
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  #555  
Old Posted May 23, 2009, 8:12 PM
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As requested, here's the link for the Waterloo stat

Thanks for posting that article from the Spec. It took a bit of digging but I found the full text of it (it's quite long with the tables at the end included):

What would it be worth? TheSpec.com - Local - What would it be worth?
Study says a team in Hamilton could reach $600m in market value

Joan Walters
The Hamilton Spectator

(May 23, 2009) The business of hockey can be a treacherous undertaking -- just ask the Phoenix Coyotes. They have been hemorrhaging money for years.

But potential revenue streams available to team owners, arena managers, suppliers and others is nothing to be sneezed at.

Especially in Canada. The hands-down most profitable team for years has been the Toronto Maple Leafs; and the top 10 teams by value include Montreal and Vancouver.

BlackBerry billionaire Jim Balsillie has been trying for years to bring a team to Hamilton to serve southern Ontario. And it's not just because he's a lifelong hockey player and a believer in the game.

A study released last fall says a second NHL team in the region could mean big bucks. SportsCorp Ltd., a Chicago-based sports consulting firm, found that a team here could have a market value of $400 million to $600 million, after factoring in what the Leafs are worth, and whether the market could absorb another team.

Balsillie's acquisition of the Coyotes for $212.5 million US could be an especially shrewd investment.

The Phoenix team has been weighed down by financial problems almost since the beginning, despite hot prospects when it first got off the ground in the NHL's sunbelt expansion.

A copy of the Phoenix team consortium's Arena Management and Lease Agreement, filed in Arizona as part of owner Jerry Moyes's bankruptcy filing, shows the potential that seemed to exist.

Without providing specific income expectations, it cites many of the game's traditional revenue streams, including licensing, arena naming rights, tickets, premium seats and suites, and concessions, such as food and beverage.

But in Phoenix, some of that promise was never realized.

Even so, the city of Glendale claims that an offer to keep the ailing team in Arizona - thought to be in the range of $130 million - would actually produce better financial results than a move to Canada. That's because Glendale, a Phoenix suburb, could launch a claim for about $500 million US against the Coyotes for failing to live up to an agreement to play until 2035 at the Jobing.com arena, named for a Phoenix-based job recruiter.

That 10-year, $30-million corporate name deal was struck in 2006, about three years after the arena opened. The team's annual losses have been in the range of $20 million to $30 million US.

The city of Glendale sought a court injunction Thursday to prevent the team's move.

It says in the filing that a recent study conservatively estimates the team's economic impact on the city at 540 jobs, $199 million in industry output, $38 million of "value added" in labour income property tax income and business taxes, and $1.2 million in sales tax.

Attendance in Phoenix has been sagging, though, not a good thing for the league, since about 50 per cent of NHL revenue is tickets.

Hockey-mad Canadians might remedy the problem.

Last year, an NHL report on ticket revenues for its 30 teams showed the six Canadian franchises account for almost a third of the $1.1 billion US in ticket revenue.

In Hamilton, sell-out games are taken as a strong possibility.

Even though Copps Coliseum is not up to NHL standards - and costly renovations would be needed - it is anticipated ticket prices would be in line with the rest of the league. In 1997, when a publicly-backed consortium tried for an NHL expansion team, the plan was to fit Copps with 93 private boxes, each leased for $78,000 a season.

In 1997 dollars, the annual net take from suites alone would have been $6 million.

All in, it was anticipated that an NHL team starting play in 1998-99 could turn an annual profit of $7 million to $8 million, based on revenues of up to $67 million a year in its first five years.

Forbes magazine's 2008 annual report on the NHL places Calgary Flames at No. 8 for operating income of $7 million US.

It is conceivable that a Hamilton team would rank right up there within the league's top 10.

jwalters@thespec.com
905-526-3302
With spectator wire services


THE LATEST OBSTACLE?
Two New York senators wrote to NHL commissioner Gary Bettman on Thursday siding with the league in its bid to prevent the move to Hamilton. The Sabres, one of the NHL's strongest U.S. small-market franchises, generates about 20 per cent of revenue from across the border in Ontario - fans who would presumably keep their wallets in Canada if there were a local team.

Team values
1 Toronto Maple Leafs 448
2 New York Rangers 411
3 Montreal Canadiens 334
4 Detroit Red Wings 303
5 Philadelphia Flyers 275
6 Dallas Stars 273
7 Boston Bruins 263
8 Vancouver Canucks 236
9 Colorado Avalanche 231
10 New Jersey Devils 222
11 Minnesota Wild 217
12 Los Angeles Kings 210
13 Ottawa Senators 207
14 Chicago Blackhawks 205
15 Calgary Flames 203
16 Anaheim Ducks 202
17 Tampa Bay Lightning 200
18 Pittsburgh Penguins 195
19 San Jose Sharks 179
20 Edmonton Oilers 175
21 Buffalo Sabres 169
22 Carolina Hurricanes 168
23 Nashville Predators 164
24 Florida Panthers 163
25 St. Louis Blues 162
26 Washington Capitals 160
27 Atlanta Thrashers 158
28 Columbus Blue Jackets 157
29 New York Islanders 154
30 Phoenix Coyotes 142
Value in US million dollars based on current arena deal (unless new arena is pending) without deduction for debt


Source: Forbes magazine NHL Report, 2007-08 season


Operating income
1 Toronto 66.4
2 Montreal 39.6
3 New York Rangers 30.7
4 Vancouver 19.2
5 Dallas 14.2
6 Detroit 13.4
7 Edmonton 11.8
8 Calgary 7.4
9 Pittsburgh 5.1
10 Ottawa 4.7
Value in US million dollars.


The Forbes list calculates operating income as earnings before interest, taxes, depreciation and amortization.


Average ticket price
Toronto 76.15
Montreal 64.26
Vancouver 62.05
Boston 61.40
Minnesota 61.28
Philadelphia 60.25
New Jersey 57.15
Calgary 55.81
New York Rangers 54.96
Edmonton 54.17
Florida 52.61
Chicago 52.22
Pittsburgh 51.45
NHL AVERAGE 49.66
New York Islanders 48.84
Ottawa 48.82
Atlanta 48.51
Columbus 47.76
Nashville 47.22
Los Angeles 47.20
Detroit 46.60
Anaheim 43.50
San Jose 43.07
Tampa Bay 42.41
Washington 41.66
Colorado 40.62
Carolina 38.38
Dallas 37.80
Phoenix 37.45
Buffalo 36.43
St. Louis 29.94
Source: Team Marketing Report, 2008
Values in US million dollars.



What value Copps?
It's been speculated that Copps Coliseum might carry a different moniker if an NHL team arrives. That's because arena naming rights are an attractive sponsorship opportunity for major corporations. They pay big money to affix their names and logos.


It was William Wrigley, the chewing gum magnate and owner of the Chicago Cubs, who started the trend in the 1920s. He elected to name the park Wrigley Field. Today about 90 per cent of NHL teams play in a name-sponsored arena.


Here are some NHL arena examples:
* Prudential Financial purchased the naming rights for the Prudential Center, in New Jersey, in January 2007 for $105.3 million over 20 years.
* The Maple Leafs play in Toronto's Air Canada Centre. Naming cost for the airline: $40 million over 20 years.
* Carolina Hurricanes also have a Canadian-based name sponsor. They play in the RBC Centre. The Royal Bank of Canada paid $80 million for 20-year rights.
* The cost of a naming rights and promotional sponsorship deal for the Pepsi Center, where Denver plays, was about $68 million.
Source: hockey.ballparks.com, NHL, Spectator file
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  #556  
Old Posted May 23, 2009, 10:56 PM
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What about the possibility that a Hamilton/Buffalo rivalry will bring more Hamiltonians to Buffalo games than currently attend? If I had to guess, I'd say that Buffalo ticket prices would be significantly lower, and it might be a more affordable means of watching the Hamilton team play.

Has anyone considered this?
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  #557  
Old Posted May 24, 2009, 1:18 AM
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I'm still pretty nervous about this rally next Saturday. I am all over the whole NHL/Balsillie story, but I have not heard much about the rally and I do not know who is organizing it. I am guessing that most people have no idea that it is taking place. I really hope this thing picks up some steam.
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  #558  
Old Posted May 24, 2009, 3:24 AM
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Originally Posted by BCTed View Post
I'm still pretty nervous about this rally next Saturday. I am all over the whole NHL/Balsillie story, but I have not heard much about the rally and I do not know who is organizing it. I am guessing that most people have no idea that it is taking place. I really hope this thing picks up some steam.
Yeah, I'd really like to know what's going on there. I did a little Googling earlier today and found nothing.
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  #559  
Old Posted May 24, 2009, 5:28 AM
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  #560  
Old Posted May 25, 2009, 11:09 AM
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Balsillie would forgo NHL aid if Coyotes moved here

May 25, 2009
Steve Milton
The Hamilton Spectator
http://www.thespec.com/News/Local/article/571505

BlackBerry baron Jim Balsillie will this week officially file an application with the NHL to move the Phoenix Coyotes to Hamilton.

And he's also willing, if the National Hockey League so desires, to forgo dipping into the league's revenue-sharing pool.

Balsillie's team is ready to make that concession because they are confident the Hamilton market will offer enough support from an eager fan base to make it a profitable venture.

Balsillie filed an application with the NHL to buy the Phoenix Coyotes late last week, and early this week he'll officially apply to the league to move the team to Hamilton.

So what exactly are the conditions the NHL will require him to meet before relocating the team?

Although he'd agreed to buy the Coyotes from Jerry Moyes as part of Moyes' contentious bankruptcy claim, Balsillie hadn't filed any applications to the NHL until Judge Redfield Baum told him to last week.

While the details in Balsillie's application to move the team and of a court filing he'll make before June 13 aren't yet known, an earlier court document filed by Moyes and the Coyotes offers a window into the argument the Balsillie camp will mount.

Last week, the Coyotes filed a document which deals, almost point by point, with Section 36 of the NHL bylaws pertaining to franchise relocation.

While Balsillie promised two years ago in his drive to buy and move the Nashville Predators not to accept his portion of NHL revenue sharing in Hamilton, should the team qualify, there is no such concrete promise in Moyes' filings, nor is there likely to be in Balsillie's documents.

But there was a fuzzy reference to it when the Coyotes answered the bylaw requirement that a prospective owner can absorb any early losses in a new location.

"(Balsillie) is willing to and able to sustain losses during the initial years of operation (in Hamilton), and is further committed to operate profitably without subsidy from other NHL teams," the Coyote filings said.

Yesterday, Balsillie's spokesperson Bill Walker told the Spec,"We anticipate operating profitably in Hamilton by bringing NHL hockey to the best unserved hockey market in the world and therefore not drawing on revenue sharing under the CBA (Collective Bargaining Agreement). Our support from more than 130,000 fans and growing on www.makeitseven.ca tells us there's great demand for a seventh NHL team in Southern Ontario."

The first factors member clubs are supposed to take into account in a proposed relocation are whether the franchise has any reasonable chance to be viable in its current location and whether new ownership would make a difference in that location.

In response, the Coyotes point to the $300 million owner Jerry Moyes has sunk into the club, the $73 million the team has lost during the past three years and that "no prospective owner or investor has stepped up with a plan to make the club financially viable in Phoenix."

Here are the Coyotes' other key replies to major points of consideration in the league bylaws:

* The extent to which fans have historically supported the team in its current location:

The Coyotes point to the team's 24th overall ranking in NHL attendance, its low ratio of ticket revenue to overall revenue (fluctuating between 40.7 and 43 per cent, compared with an NHL average of roughly 50 per cent) and the low average ticket price ($12.21 below the NHL average) that the Coyotes must charge in order to attract fans.

* Whether the current owner has made a good-faith effort to find prospective purchasers who are prepared to continue operating the club in its current location:

The Coyotes answer that Moyes has tried to find an owner for a year and, at the NHL's suggestion, hired Citibank Banking Group to help sell the team. But no offer could be found that would take care of creditors and keep the team in the desert. The NHL will certainly counter that with the Jerry Reinsdorf offer and recently revealed interest in the team from minority owner John Breslow.

* The extent to which the club might be operated in its current location in a more prudent manner.

The Coyotes answer brusquely that the Coyotes' financial problems are not due to mismanagement. The team has taken several cost-cutting measures, including reducing staff; it has tried (unsuccessfully) to get arena-lease concessions from the City of Glendale; and it used younger players in order to have the fourth-lowest payroll in the league-- $25 million less than top-spending New York Rangers. However, since the Coyotes filed this brief, Glendale has said it will make lease concessions that will make the team financially viable at Jobing.com Arena.

* Whether there will be a suitable arena available to the relocated club:

NHL Commissioner Gary Bettman has taken to referring to it as "antiquated," but Coyotes say Copps Coliseum, with a 17,326 capacity for hockey, is suitable for NHL hockey and point out that funding for substantial rink improvements is being arranged.

* The extent to which the proposed transfer would harm the image of the NHL as a major league:

The Coyotes team says the NHL's image will actually improve by "immediately resolving the bankruptcy of a member team." They also point to the additional rivalries created by a new team in Ontario, which would increase the number of paid fans of both home and away Coyotes games.

* The extent to which it appears likely, based on population, demographics and interest in hockey ... that support for a franchise (in Hamilton) will make it financially viable:

Both camps -- the Coyotes and Balsillie -- consider this a "slam dunk" and argue the area has a population of more than 7 million "a substantial percentage of which are likely to be avid hockey fans."

When Balsillie files his application, it's likely to contain far more detail about the Hamilton market and Copps Coliseum than the Coyotes' court submission did.

If the issue ever comes to a vote of NHL governors, Balsillie would need 75 per cent in favour to be accepted as an owner, and a simple majority to relocate the team. However, the Coyotes argue that the bylaws also contain a clause that allows a territorial veto -- in this case by the Toronto Maple Leafs--and that is the heart of their antitrust allegations.
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