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It is, perhaps, ironic that an arbitrator would invalidate a freely-negotiated contract. Arbitration is, after all, governed by the principle of freedom of contract. But that is exactly what Richard Bloch did on August 9, 2009, ruling that the 17-year, $102 million contract Ilya Kovalchuck signed with the New Jersey Devils was an invalid circumvention of the NHL's collective bargaining agreement ("CBA"). Bloch's decision answered a question that had been brewing since the National Hockey League ("NHL") and National Hockey League Players' Association ("NHLPA" or "the Association") came to an agreement on a new CBA in 2005, a question that was asked every time a player signed a frontloaded contract designed to expire well after he retired: How much was too much?

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