The key distinction, in my mind, is that the NCAA and its members were found to be engaging in interstate commerce and therefore the membership is subject to the Sherman Act. Because of the recruiting element, the members were essentially price fixing their labor costs by agreeing to rules like no full cost of attendance scholarships. NIL has been rolled into that general framework. Would Indiana courts want to import that same framework into high school athletics, I doubt it. Since recruiting is not a part of the game, there can be no price fixing argument.