2013 HOCKEY ARBITRATION COMPETITION OF

New York Rangers v

Brief Submitted on Behalf of Mats Zuccarello

Team 31

Table of Contents

Introduction………………………………………………………………………………………1

Overall Performance of the Player……………………………………………………………...1

Number of Games Played and Injury History…………………………………………………2

Length of Service in the NHL and with the Club……………………………………………...3

Overall Contribution to the Club……………………………………………………………….3

Special Qualities of Leadership or Public Appeal……………………………………………..4

Comparable Players……………………………………………………………………………..4

A) Cam Atkinson………………………………………………………………………...5

B) Carl Hagelin…………………………………………………………………………..7

Valuation & Conclusion…………………………………………………………………………8

Introduction This brief is in regards to the past performance of Mr. Mats Zuccarello (the “Player”) of the (the “Club”) for the matter of salary arbitration pursuant to Article

12.1(a) of the 2013 Collective Bargaining Agreement (the “CBA”) between the National Hockey

League (the “NHL”) and the ’s Players Association (the “NHLPA”).

The CBA states in section 12.9(g)(ii) seven categories of evidence that is admissible in salary arbitration cases: the overall performance of the player in previous seasons; the of games played in previous seasons and any injuries or illnesses; the length of service of the player in the NHL and/or with the Club; the overall contribution of the player to the Club’s competitive success or failure; any special qualities of leadership or public appeal; the overall performance of any player(s) alleged to be comparable to the Player and the compensation of any players alleged to be comparable.

As we will show in this brief, Mr. Zuccarello, due to the above factors, should be compensated with a salary of $1,300,000.

All statistics used in this brief are obtained from www.nhl.com, unless otherwise noted.

Overall Performance of the Player Table 1: Mats Zuccarello Career Statistics GP G A P PPG +/- PIM TOI/G

2010-11 42 6 17 23 0.55 3 4 14:10

2011-12 10 2 1 3 0.30 0 6 10:02

2012-13 15 3 5 8 0.53 10 8 16:25

Career Totals 67 11 23 34 0.51 13 18 14:04

Mr. Zuccarello is considered an offensive player and reached career highs in games played, goals, assists, points and points-per-game (“PPG”) in his rookie season in 2010-11 with

1 42 games, six goals, 17 assists and 23 points, resulting in a PPG of 0.55, 0.04 higher than his career average of 0.51.

His next season in 2011-12 was split into two segments separated by his time during which he was assigned to the (the “AHL”).1 After being scoreless in three games in his first stint, Mr. Zuccarello recorded 2 goals and 3 points in 7 games, a 0.43

PPG, 0.08 less than his career average. His average for the entire season was even lower at 0.30.

However, his TOI/G was the lowest of his career at 10:02, more than 4 minutes less than his career average, a possible explanation for this drop in production.

In his platform season, the lockout-shortened 2012-13 season, Mr. Zuccarello had career highs in +/- with 10 minutes with eight and TOI/G with 16:25. He also approached his career high PPG with 0.53, 0.02 less than his rookie season, but 0.02 more than his career average.

Number of Games Played and Injury History In his rookie season, Mr. Zuccarello spent the first half playing in the AHL for the

Connecticut Whale until he was recalled by the Rangers on December 22nd. He then proceeded to play 42 of the 47 games remaining, missing 3 games as a result of being re-assigned to the AHL from April 1st to 8th.2

The following season, Mr. Zuccarello played three games in the NHL, recording no points, and then was assigned to the Rangers’ American Hockey League (the “AHL”) affiliate, the Whale, where he spent the majority of the season. He was recalled on March 11,

2012 and proceeded to play 7 games before sustaining a fractured wrist, forcing him to miss the remainder of the season.3

1 http://www.tsn.ca/nhl/teams/players/bio/?id=7214 2 Supra note 1 3 Supra note 1

2 In his platform season, the lockout-shortened 2012-13 season, Mr. Zuccarello played in all 15 games after re-signing with the Rangers on March 26, 2013. Mr. Zuccarello spent the majority of the season playing in the Kontinental Hockey League (the “KHL”) until coming to terms on a contract with the Rangers.4

Length of Service in the NHL and with the Club Mr. Zuccarello has been a member of the New York Rangers Organization and player in the NHL since signing with the Club as a free agent on May 26, 2010. The Rangers’ retained his

NHL rights after his time spent with Magnitogorsk of the KHL in 2012-13.

Overall Contribution to the Club Although Mr. Zuccarello has only played in 67 games over the past three seasons, he has made a significant contribution to the Club and its success.

In his rookie season, Mr. Zuccarello lead the team with nine power play assists, five shootout goals and three shootout-winning goals.5 As well, the Rangers were 4-1-0 in games when he scored a , and 13-4-1 in games when he registered at least one . Two of Mr.

Zuccarello’s six goals were also game-winning goals. Mr. Zuccarello finished tied for 13th in team scoring and 11th among forwards, despite only playing 42 games, less than anyone who scored more. The Rangers finished eighth in the Eastern Conference with 93 points, making the playoffs.

In the 2011-12 season, one of Mr. Zuccarello’s two goals was a game-winning goal. The

Rangers finished first in the Eastern Conference with 109 points. The Rangers were 2-1 in games where Mr. Zuccarello registered a point, and were 4-1 in games where Mr. Zuccarello played at least 10 minutes.

4 Supra note 1 5 http://rangers.nhl.com/club/player.htm?id=8475692&view=bio

3 In his platform season, Mr. Zuccarello finished 13th in team scoring and 9th among forwards, despite only playing 15 games. The Rangers were 10-4-1 in games Mr. Zuccarello played in and 5-2 in games Mr. Zuccarello registered a point. The Rangers finished sixth in the

Eastern Conference with 56 points, their third straight season in the playoffs. Mr. Zuccarello was a major contributor during the playoffs, leading the team in power play assists, with three, and second on the team in assists and points, with 6 assists and 7 points in 12 games, a PPG of 0.58, an increase on his regular season PPG of 0.53 and career average of 0.51. This performance showed Mr. Zuccarello’s ability to elevate his play during important games. The Rangers advanced to the Eastern Conference Semi-Finals, losing to the eventual Conference Champions, the . The Rangers were 4-2 in the playoffs when Mr. Zuccarello recorded a point, including all four wins in their first round victory over the third-seeded .

Special Qualities of Leadership or Public Appeal Although it is difficult to quantify any special qualities of public appeal, Mr. Zuccarello has certainly attained some public appeal due to his recent playoff success, as is shown by his

39,051 followers on .6

While playing in , Mr. Zuccarello led the Swedish Elitserien or “Elite League”

(the “SEL) in scoring and won the Guldhjälmen award as the league’s Most Valuable Player in

2009-10. Mr. Zuccarello has also represented his country, Norway, on the international stage at the 2010 Winter Olympics, as well as the IIHF World Championships in 2008, 2009, and 2010.7

Comparable Players Given Mr. Zuccarello’s overall performance, age, and contribution to the New York

Rangers over a minimal length of service, there are limited comparable players available. Mr.

Zuccarello’s worth is assessed below with respect to two players that were found.

6 https://twitter.com/zuccarello36 7 Supra note 5

4 A) Cam Atkinson Mr. Cam Atkinson signed a 2 year contract worth $2,300,000 with the Columbus Blue

Jackets in 2013, with an average annual value of $1,150,000.8 Mr. Atkinson was 24 years of age during the offseason in which his contract was signed, 1 year younger than Mr. Zuccarello. Mr.

Atkinson and Mats. Zuccarello are very similar players as they are both undersized wingers with the potential to play regularly on the top two lines for their respective teams. Both players are considered to be of value on the power play and play on their respective teams’ second power play units.

Table 2: Career Statistics Player GP G A P PPG +/- PIM TOI/G Mats Zuccarrello 67 11 23 34 0.51 13 18 14.04 Cam Atkinson 62 16 16 32 0.52 10 18 15.30 Table 3: Platform Year Statistics Player GP G A P PPG +/- PIM TOI/G Mats Zuccarello 15 3 5 8 0.53 10 8 16.25 Cam Atkinson 35 9 9 18 0.51 9 4 15.35 Mr. Atkinson’s prior 62 NHL game total is very similar to Mr. Zuccarello’s 67 game total. In his 62 games, Mr. Atkinson recorded 16 goals, 16 assists, and 32 points. Mr. Atkinson’s

0.52 career PPG is nearly identical to Mr. Zuccarello’s 0.51 career PPG. Mr. Atkinson’s platform year PPG of 0.51 is slightly lower than Mr. Zuccarello’s platform year PPG of 0.53. However, given the minimal number of games both players played, these negligible differences in PPG figures should not be used as material evidence in deciding which player’s value is higher.

The similarities between Mr. Zuccarello and Mr. Atkinson are uncanny in terms of their stature, style of play and points statistics. This suggests that Mr. Zuccarello should earn a similar salary to Mr. Atkinson’s average annual value of 1,150,000. However, Mr. Zuccarello’s recent performance in pressure situations and meaningful games indicates that his salary should be

8 http://capgeek.com/player/1954

5 slightly higher. In his platform season, Mr. Zuccarello was a major contributor in the playoffs as he elevated his game and recorded the second highest points total for the New York Rangers with 7 points in 12 games. He was a major contributor to the Rangers playoff run as they advanced to the Eastern Conference semi-finals. It should be noted that while Mr. Zuccarello’s playoff performance warrants a higher salary, the increase above Mr. Atkinson’s average annual value should be within reason since Mr. Atkinson has not had any playoff opportunities.

Further increase in Mr. Zuccarello’s salary above Mr. Atkinson’s annual average value is implicated by his superior power play statistics. While both players have the potential of playing regularly on their respective team’s first power play unit, Mr. Zuccarello is more likely to do so given his statistics. Despite being on a superior team with a superior power play, Zuccarello was utilized on the power play moreso than Mr. Atkinson. Mr. Zuccarello’s power play TOI per 60 minutes played by the New York Rangers was 2:29, which ranked 8th on the New York Rangers.

On the other hand, Mr. Atkinson’s corresponding power play figure was 1:28, which ranked 12th on an inferior team.9 Since offensive prowess and skill are considered to be some of the strongest attributes of both Mr. Zuccarello and Mr. Atkinson, power play time is crucial in their comparison. To further Mr. Zuccarello’s increased value on the power play, in both of their platform seasons, Mr. Zuccarello’s power play point percentage was higher at

12.5% than Mr. Atkinson’s at 11.1%. This statistic is useful when comparing players with different power play TOI/60 as it divides the player’s power play points by the number of power play opportunities, therefore allowing for an even comparison as to their power play effectiveness.

9 http://www.behindthenet.ca/nhl_statistics.php?ds=30&s=8&f1=2012_s&f2=5v4&f5=NYR&c=0+1+3+5+4+6+7+8 +13+14+29+30+32+33+34+45+46+63+67

6 B) Carl Hagelin Mr. Hagelin and the New York Rangers signed a 2 year contract in 2013 worth

$2,250,000, with an average annual value of $2,250,000.10 Mr. Hagelin serves as a very relevant comparable to Mr. Zuccarello, since both individuals are 25 year old wingers that play for the

New York Rangers.

Table 4: Career Statistics Player GP G A P PPG +/- PIM TOI/G Mats Zuccarello 67 11 23 34 0.51 13 18 14.04 Carl Hagelin 112 24 38 62 0.55 31 42 16.01 Table 5: Platform Year Statistics Player GP G A P PPG +/- PIM TOI/G Mats Zuccarello 15 3 5 8 0.53 10 8 16.25 Carl Hagelin 48 10 14 62 0.50 10 18 17.18 In 112 prior NHL games, Mr. Hagelin recorded 24 goals, 38 assists, and 62 points. Mr.

Hagelin’s career PPG of 0.55 is higher than Mr. Zuccarello’s career PPG of 0.51. Mr. Hagelin’s platform year PPG of 0.50 is lower than Mr. Zuccarello’s platform year PPG of 0.53. However, it should be noted that Mr. Hagelin played 33 more games during 2012-2013 platform season.

It is indisputable that Mr. Hagelin’s game total and PPG with New York Rangers makes him the superior player. However, while their TOI/G numbers suggest that Mr. Hagelin was given an extra 1:57 of ice time per game, these figures are slightly flawed as they do not account for games in which the New York Rangers played extra minutes in . When considering playing time with respect to total minutes played the difference in playing time is far more material. Over his career, Mr. Zuccarello has been given 11.2 minutes for every 60 minutes of team play (“TOI/60”) while Mr. Hagelin has been given 14.6 TOI/60. With these more accurate figures, the difference in playing time increases to 3.4 minutes, which is a substantial amount of time for forwards. Consequently, Mr. Zuccarello required almost 4 minutes less of ice time than

10 http://capgeek.com/player/1993

7 Mr. Hagelin to record a point in their respective platform seasons: Mr. Zuccarello’s TOI/Point figure was 30:47 compared to Mr. Hagelin’s 34:36 TOI/Point. Given these numbers, it is possible that this extra ice time could have allowed for Mr. Hagelin’s better numbers.

As well, Mr. Zuccarello was trusted with more power play duties than Mr. Hagelin, as is seen by his higher power play TOI/G of 2:24, which is 1:22 higher than Mr. Hagelin’s 1:02 and five spots higher on the team. The Rangers were right to trust Mr. Zuccarello over Mr. Hagelin in this respect, as Mr. Zuccarello’s power play percentage of 12.5% is much higher than Mr.

Hagelin’s 4.2%, showing Mr. Zuccarello was much more effective on the power play.

A comparison between Mr. Zuccarello and Mr. Hagelin’s playoff performances in the

2012-2013 season appears to lessen the difference in value between the two players further.

While Mr. Zuccarello only had one more point than Mr. Hagelin during the playoffs, he was able to do this with 2.90 less minutes than Mr. Hagelin per 60 minutes of New York Rangers play.11

Valuation and Conclusion Mr. Atkinson is without question the best comparable for Mr. Zuccarello given them being nearly identical with respect to performance, age, and stature. However, Mr. Zuccarello’s outstanding playoff performance and superior power play ability ensures that he is slightly more valuable. On the other hand, while Mr. Zuccarello is of less value than Mr. Hagelin, both Mr.

Hagelin’s significant playing time advantage and Mr. Zuccarello’s superior playoff play ensures that his superiority should not be valued at more than $1,000,000.

Given Mr. Atkinson’s average annual value of $1,150,000 and Mr. Hagelin’s average annual value of $2,250,000, Mr. Atkinson requests that he be given a yearly salary of

$1,300,000.

11http://www.behindthenet.ca/nhl_statistics.php?ds=30&f1=2012_p&f2=5v5&f5=NYR&c=0+1+3+5+4+6+7+8+13 +14+29+30+32+33+34+45+46+63+67

8