The U.S. District Court in St. Louis has dismissed a high-profile antitrust, libel and slander case against five-time World Chess Champion Magnus Carlsen of Norway.

Carlsen, surprisingly, was defeated by then-19-year-old Hans Niemann during last year’s Sinquefield Cup in St. Louis. The world champion accused Niemann of cheating and demanded his disqualification from the tournament. When Niemann was allowed to stay, Carlsen withdrew from the competition. He later refused to play against Niemann again, which Niemann claims put a significant damper on his chances of getting invited to meaningful tournaments and advancing his career, given that most tournaments would likely prefer having the games’ biggest star attend.

The situation even made it difficult for Niemann to compete online, he claimed, given that Carlsen sold his online chess platform, Play Magnus, to the world’s leading online chess platform, Chess.com, last year and became an ambassador for the site.

In the months following Carlsen’s September Sinquefield Cup defeat, Carlsen and others, including codefendant Hikaru Nakamura – a well-known chess player and Chess.com live streamer – made public statements questioning the trustworthiness of Niemann, who has admitted to cheating in online games when he was younger but maintains his innocence in the Carlsen game and other “over-the-board” competitions.

Chess.com eventually banned Niemann from the site for his past cheating and the current allegations.

As a result of what Niemann described as a defamation campaign and a violation of federal antitrust laws by monopolizing the “Competitive Chess Market,” Niemann said he was effectively blacklisted from the world of competitive chess.

Niemann sought damages of not less than $100 million related to the defamation claims and treble damages related to the antitrust claims.

But on Niemann’s second amended complaint, Judge Audrey G. Fleissig on June 27, 2023, dismissed the two counts involving antitrust violations with prejudice, essentially stating that antitrust had nothing to do with this case.

“Niemann fails to plausibly allege an antitrust injury. Again, Niemann defines the Competitive Chess Market as ‘professional chess tournaments and online recreational chess platforms,’” Fleissig stated in the order to dismiss. “But Niemann’s alleged injuries are not connected to any harm to competition in this market. Indeed, Niemann does not even compete in this market as he operates neither a professional chess tournament nor an online recreational chess platform.”

Additionally, the court found Niemann’s monopolization argument weak, as Niemann did not dispute that there are a variety of other online chess platforms and provided “little to no information” about Chess.com and Play Magnus’s share of the market. Finally, Chess.com’s enforcement of its anti-cheating rules would not constitute an illegal boycott.

Since all federal claims were dismissed, Fleissig declined to exercise supplemental jurisdiction over the defamation claims under state law, dismissing those claims without prejudice.

“We are pleased the Court has rejected Hans Niemann’s attempt to recover an undeserved windfall in Missouri federal court, and that Niemann’s attempt to chill speech through strategic litigation in that forum has failed,” said Carlsen’s New York, NY-based lead defense counsel Craig Reiser of Axinn, Veltrop & Harkrider in a statement.

New York, NY, attorney Andrew J. Urgenson of Oved & Oved, who represented Niemann, did not respond to requests for comment.

The case is Niemann v. Carlsen et al, 4:22-cv-01110-AGF

Editor’s note: A previous version of this article misspelled Judge Audrey G. Fleissig’s last name and misstated the location of Craig Reiser.

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