Skadden represented the Professional Rodeo Cowboys Association (PRCA) in defeating a preliminary injunction application brought by the Elite Rodeo Association (ERA) and its athlete-owners. The ERA, which was founded by some of PRCA's most popular rodeo athlete members and announced in September its plan to produce a competing rodeo tour, accused the PRCA board of excluding competition by adopting bylaws denying membership to owners of competing rodeo associations. On February 4, Judge Barbara M.G. Lynn of the U.S. District Court for the Northern District of Texas denied the plaintiffs' application and refused to enjoin implementation of the new bylaws, finding that the ERA was not likely to succeed on its Sherman Act claims because the PRCA board is not dominated by horizontal competitors and the ERA had failed to demonstrate that the PRCA has monopoly power.