Absent a limited antitrust exemption, which only the Congress can provide, the NCAA will continue to be the target of antitrust lawsuits whenever it tries to implement educationally defensible reforms that have commercial consequences. However, such an exemption must include conditions that protect athletes from being academically and economically exploited and require extensive college athlete protection from athletic injury and physical and psychological abuse. Further, athletes must be allowed to continue to bring antitrust actions to protect their education benefits, outside employment and NIL compensation freedoms apart from their limited permission to grant NIL use for participation in collegiate athletic events.