IN THE MATTER OF SALARY ARBITRATION BETWEEN:

MATS ZUCCARELLO

-AND-

THE RANGERS

SUBMISSION ON BEHALF OF

TEAM 32

I. INTRODUCTION AND OVERVIEW ...... 1

A. Well-Rounded and Impactful Player ...... 1

B. Significant Contributor to Team Success ...... 2

C. Shootout Specialist ...... 3

II. VALID COMPARABLE PLAYERS ...... 4

A. – Flames ...... 4

B. – ...... 6

C. Cam Atkinson – ...... 7

III. CONCLUSION ...... 8 I. INTRODUCTION AND OVERVIEW

Pursuant to section 12.9 of the NHL Collective Bargaining Agreement,1 this brief will analyze the performance and contributions of the ’ Mats Zuccarello. Despite playing in a relatively small of games over the past three seasons, Mr. Zuccarello has had a considerable impact on the Rangers, in large part due to his combination of speed, skill, tenacity and defensive awareness. As such, Mr. Zuccarello respectfully submits he is entitled to an award above the $1.15 million midpoint figure—specifically, $1.5 million per .

A. Well-Rounded and Impactful Player

Mr. Zuccarello has spent a limited amount of time in the NHL. Playing in only 67 games over his career, there is not a large sample size to discuss.2 However, despite this limited number of games, Mr. Zuccarello has established himself as an impactful NHL player. Last year, after returning from Russia’s Kontinental Hockey League (KHL), Mr. Zuccarello stepped into the lineup and provided the Rangers with an offensive spark, recording 3 goals and 5 assists for a total of 8 points in only 15 regular season games.3 Over his career, Mr. Zuccarello has averaged more than half a per game (34 points in 67 games).4 He has also proven he can produce at the most difficult and important time of the year—the playoffs. During last year’s playoff run,

Mr. Zuccarello was second on the Rangers in scoring with a total of 7 points in 12 games, more than the likes of , , Ryan Callahan and Derek Stephan. Mr. Zuccarello was also tied for first in powerplay assists and powerplay points.5 This impact is even more impressive when considering it was at the expense of two very good, but different teams. First was the Capitals, an offensive juggernaut led by 3-time MVP Alex Ovechkin, and

1 NHL Collective Bargaining Agreement, 2005, s.12. 2 ww..com/ice/playerstats 3 Ibid. 4 Ibid. 5 Ibid. 1 superstars Nicklas Backstrom and Mike Green. The following round was against the

Bruins, a big and physical defensive-minded team led by Zdeno Chara, a winner of the Norris

Trophy for best , and , a winner of the Selke Trophy for best defensive forward.6

Mr. Zuccarello has also proven he is more than just a point producer. Despite his small stature, his game has a physical edge. In 15 regular season games last season, Mr. Zuccarello registered 27 hits. He then registered another 22 in the playoffs.7 Furthermore, his defensive astuteness led to a plus-10 rating, a noteworthy accomplishment in only 15 games.8 Likewise, in three partial seasons in the NHL, Mr. Zuccarello has never been a minus player. Mr. Zuccarllo’s defensive awareness is also evident by his 15 blocked shots last season, second most amongst

Rangers’ forwards on a per game basis, behind only Ryan Callahan, who led all NHL forwards in blocked shots by a staggering 15.9 Although this sacrifice can sometimes lead to injuries, which was the case in March 2012 when Mr. Zuccarrello broke his wrist while blocking a and was forced to miss the playoffs, it undoubtedly adds to the defensive effectiveness of any player.10 Given his contributions at both the offensive and defensive end, Mr. Zuccarello submits he is entitled to an award greater than the $1.15 million midpoint figure.

B. Significant Contributor to Team Success

Despite his short time in the NHL, Mr. Zuccarello has had a dramatic impact on the success of the New York Rangers. For example, after Mr. Zuccarello returned to the lineup on

March 30, 2013, the Rangers went 10-4-1 in their final 15 games.11 This was in stark contrast to

6 http://www.nhl.com/ice/page.htm?id=62242 7 Ibid. 8 Ibid. 9 www.nhl.com/ice/playerstats 10 http://www.sportingnews.com/nhl/story/2012-03-23/mats-zuccarello-injury-new-york-rangers-john-tortorella- pittsburgh-penguins 11 www.nhl.com/ice/teamstats 2 their season up to that point, where the team recorded a disappointing 16-14-3 record.12 This substantial improvement can be accredited in large part to an increase in team scoring, something

Mr. Zuccarello’s puck-handling skills and offensive creativity undoubtedly helped. For instance, before Mr. Zuccarello rejoined the team, the Rangers were averaging 2.36 goals per game.13 This total would have been the fourth worst in the NHL at year’s end, behind only Nashville, New

Jersey and Florida—all non-playoff teams. After Mr. Zuccarello returned to the lineup, the

Rangers’ average rose to an impressive 3.47 goals per game, a figure higher than that of the

Pittsburgh Penguins, who led the league in scoring with a 3.44 goals per game average.14

C. Shootout Specialist

When shootouts were added to the NHL following the 2005 lockout, teams were forced to consider another skill when assembling their rosters. What quickly became apparent was the fact the NHL’s best offensive players were not necessarily productive in a shootout, as evinced by the career conversion rates of (25%), Martin St. Louis (21.9%) and Jaromir Jagr

(25%).15 Mr. Zuccarello’s career 50% conversion rate (6 of 12) is bettered by only four active players with at least 10 attempts.16 Furthermore, of his six goals, four have been game-deciding goals, an incredibly high ratio and a testament to Mr. Zuccarello’s ability to handle pressure.

With the increasing competitiveness of the NHL in recent years, the extra point available in the shootout in extremely important. For example, last season the Rangers finished 6th in the

Eastern Conference with 56 points. However, the difference between the 5th place Maple

Leafs (57 points) and the 8th place (55 points) was incredibly minute.17 Two

12 Ibid. 13 Ibid. 14 Ibid. 15 http://www.nhl.com/ice/shootoutstats 16 Ibid. 17 www.nhl.com/ice/standings 3 shootout goals over the course of the season could have made the difference between four places in the standings. An even better example of the immense value of Mr. Zuccarello’s shootout ability is evident when examining the Rangers’ 2010-2011 season. That year the team finished

8th in the Eastern Conference, securing the final playoff spot by only two points over the 9th place

Carolina Hurricanes. When the standings are examined further, it is clear that shootouts were a big reason for this two-point difference, as the Rangers won 9 of their 12 shootouts, whereas the

Hurricanes won only 5 of 10.18 These nine shootout wins were only one behind the league lead.19

Mr. Zuccarello was a predominate reason for the Rangers’ success, scoring 5 goals on 9 attempts, tying for the team lead in shootout goals (5) and game deciding goals (3), despite playing only half the season.20 The Rangers’ shootout victories not only gave them a chance to win the , it also earned an estimated $2 million in profit from their two guaranteed home games, plus another $500,000 for each playoff game aired on the MSG Network.21

II. VALID COMPARABLE PLAYERS

A. Mikael Backlund –

Finding Valid Comparable Players for Mr. Zuccarello is difficult, as very few arbitration eligible players have managed to have such a dramatic impact on the outcome of their team’s games while playing in the limited number he did. One possible comparable is Mikael Backlund of the Calgary Flames, who signed a two-year deal worth $1.5 million per year in July.22

Comparing statistics from last season, both players’ platform year, and their careers in general, reveals many similarities. For example, in 32 games last season, Mr. Backlund scored 16 points, for an average of 0.5 points per game. In 15 games, Mr. Zuccarello scored 8 points, for an

18 www.nhl.com/ice/teamstats 19 Ibid. 20 www.nhl.com/ice/playerstats 21 http://www.crainsnewyork.com/article/20110413/FREE/110419934 22 www.capgeek.com 4 average of 0.53 points per game.23 Mr. Backlund’s highest point total came in 2010-2011, when he recorded 25. That same year, Mr. Zuccarello recorded a career-high 23 points. However, Mr.

Backlund accomplished the feat in 71 games, whereas Mr. Zuccarello recorded his career high while playing only 42 games.24 When examining their careers as a whole, Mr. Backlund has a points per game average of 0.36, whereas Mr. Zuccarello has a considerably higher points per game average of 0.51.25 Furthermore, over his career Mr. Zuccarello has amassed a plus-13 rating, whereas Mr. Backlund has a minus-10 rating.26

There are also differences when comparing how much and in what capacity each player is utilized by their respective clubs. For example, last season Mr. Backlund played an average of

15:07 per game, much less than Mr. Zuccarello’s average of 16:25.27 This difference is more significant when considering the sizeable difference between the number of talented forwards on the playoff-bound Rangers and the lack thereof on the Flames, who finished 13th in the Western

Conference. Mr. Zuccarello also averaged over a minute more on the powerplay than Mr.

Backlund (2:24 and 1:23 per game, respectively).28 While Mr. Backlund may have spent more time on the kill, averaging 0:23 per game, this had to do with the fact the Flames were rebuilding and gave nearly all players a chance to kill penalties at some point.29 In fact, Mr.

Backlund’s 0:23 per game on the penalty kill ranked 14th among all Flames forwards, revealing his limited use and importance in that area of the game.30

While Mr. Backlund has had a longer NHL career to this point, there are several other factors that show Mr. Zuccarello is worthy of at least equal, if not greater compensation. First,

23 www.nhl.com/ice/playerstats 24 Ibid. 25 Ibid. 26 Ibid. 27 Ibid. 28 Ibid. 29 Ibid. 30 Ibid. 5

Mr. Backlund has a history of injuries. In fact, over the last two seasons alone, he has missed a total of 57 games with a myriad of health problems, including injuries to his shoulder, knee, foot and finger.31 Second, unlike Mr. Zuccarello who has had a great deal of playoff success during his short career, Mr. Backlund has yet to play a single playoff game. Finally, while Mr.

Zuccarello helps secure extra points for his team with his shootout prowess, Mr. Backlund does not do the same, going 0 for 2 in shootout attempts over his career.32 Given both the similarities and differences between these two players, Mr. Zuccarello submits he is entitled to an awarded at least equal to Mr. Backlund’s $1.5 million salary.

B. Matt Beleskey – Anaheim Ducks

Another comparable to Mr. Zuccarello is Matt Beleskey of the Anaheim Ducks, who signed a two-year deal worth an average of $1.35 million this summer.33 Like Mr. Backlund, Mr.

Beleskey has had a longer NHL career than Mr. Zuccarello. However, also like Mr. Backlund,

Mr. Beleskey has failed to have as dramatic an impact on his club’s success as Mr. Zuccarello. In fact, when the numbers from last year’s platform seasons are compared, Mr. Zuccarello is equal or better than Mr. Beleskey in almost every area. For example, while both players do not kill penalties, Mr. Zuccarello spent an average of nearly four and a half minutes more on the ice than

Mr. Beleskey (16:25 versus 12:00 per game) and over a minute and a half more on average on the powerplay (2:24 versus 0:49 per game).34 While Mr. Beleskey had a higher number of hits per game (2.45 versus 1.8), Mr. Zuccarello had a higher number of shot blocks per game (1.0 versus 0.38).35 Furthermore, while Mr. Beleskey amassed a plus-2 rating in 42 games, Mr.

31 http://www.tsn.ca/nhl/teams/players/bio/?id=6417; http://www.calgaryherald.com/sports/hockey/calgary- flames/Flames+sign+forward+Mikael+Backlund+twoyear/8642417/story.html. 32 http://www.nhl.com/ice/shootoutstats 33 www.capgeek.com 34 www.nhl.com/ice/playerstats 35 Ibid. 6

Zuccarello was an astonishing plus-10 in 15 games. Moreover, Mr. Beleskey is minus-20 over his career while Mr. Zuccarello is plus-13.36

However, the biggest difference between these two players is their offensive ability. For instance, while Mr. Zuccarello averaged 0.53 points per game last season, Mr. Beleskey averaged only 0.31 points per game.37 In the playoffs, Mr. Beleskey was 7th on his team in scoring, whereas Mr. Zuccarello was 2nd.This difference in offensive ability is magnified when both players’ careers are examined as a whole, as Mr. Zuccerello has a points per game average of 0.51, whereas Mr. Beleskey has an average of 0.27.38 Due to this considerable difference in offensive ability alone, Mr. Zuccarello submits he is entitled an award in excess of Mr.

Beleskey’s $1.35 million salary.

C. Cam Atkinson – Columbus Blue Jackets

A third Valid Comparable Player to Mr. Zuccarello is Cam Atkinson of the Columbus

Blue Jackets, who re-signed with the team in April on a two-year deal worth an average of $1.15 million per season.39 These two players have many similarities. Both are in the infancy of their careers, having played under 70 NHL games. Both have produced at a very similar level—in 62 career games, Mr. Atkinson has scored 32 points. Similarly, in 67 career games, Mr. Zuccarello has scored 34 points.40 Both are also defensively responsible. For example, they have a similar plus/minus rating and have registered almost an identical number of blocked shots over their careers—Mr. Atkinson is plus-10 with 33 blocked shots and Mr. Zuccarello is plus-13 with 32 blocked shots.41

36 Ibid. 37 Ibid. 38 Ibid. 39 www.capgeek.com 40 www.nhl.com/ice/playerstats 41 Ibid. 7

Despite these similarities, there are important differences between Mr. Zuccarello and

Mr. Atkinson, which entitle Mr. Zuccarello to an award greater than Mr. Atkinson’s $1.15 salary.

First, Mr. Zuccarello is much more physical. In only 15 games last season, he recorded 27 hits for an average of 1.8 hits per game, whereas Mr. Atkinson recorded only 24 hits in 34 games for an average of 0.7 hits per game.42 Second, Mr. Zuccarello plays a larger role on a better team.

Last season he averaged 16:25 in ice time per game, nearly a minute more than Mr. Atkinson’s average of 15:35.43 This discrepancy is greater when you account for the fact the Rangers were a better team, finishing 5th in the Eastern Conference while the Blue Jackets finished 9th in the

Western Conference.44 Third, although serviceable in the shootout over his career (2 goals on 5 attempts), Mr. Atkinson has not had the same dramatic impact in that area on the game as Mr.

Zuccarello, who has an astounding four game deciding goals on only 12 career attempts.45

Fourth, and perhaps most important, Mr. Atkinson has never been to the playoffs, whereas last season Mr. Zuccarello finished second on the Rangers in post-season scoring.46 For these reasons, Mr. Zuccarello submits he should be awarded a salary above the $1.15 million midpoint figure, which also happens to be Mr. Atkinson’s salary.

III. CONCLUSION

Mr. Zuccarello has had a large impact on the performance of the Rangers in his short time in the NHL. He provides the team with a well-rounded and valuable skill set and has a knack for scoring when it matters most. When comparing Mr. Zuccarello with other players in the price range, it is evident that he is entitled to an award above the $1.15 million midpoint figure, and that $1.5 million presents an appropriate and fair award.

42 Ibid. 43 Ibid. 44 www.nhl.com/ice/standings 45 www.nhl.com/ice/playerstats 46 Ibid. 8