NIL
Will the SCORE Act Sideline Women Athletes? Title IX Advocates Push for NIL Protections
As appeals are filed relating to a collegiate athlete compensation settlement, these women-led groups are making sure female athletes aren’t left out.
Members of the Democratic Women’s Caucus are pushing Congress for explicit Title IX protections for women student-athletes in a proposed national law related to name, image and likeness (NIL)—and long-time gender equity advocates hope they succeed.
“I’m really concerned that we’re going back to the 1970s and earlier, before Title IX took effect,” said attorney Jayma Meyer, a visiting clinical professor and adjunct professor at the Maurer School of Law at Indiana University.
Four years into student-athletes being able to capitalize on their NIL, 32 states have enacted their own laws. Now, there is a proposed bill before Congress, the Student Compensation and Opportunity Through Rights and Endorsements (SCORE) Act, which is designed to establish a national framework for collegiate athlete compensation, particularly as it pertains to NIL.
Something the SCORE Act doesn’t take into consideration is Title IX and gender equity. Earlier this year, the Department of Education Office of Civil Rights rescinded guidance put in place by the Biden administration, noting it was “overly burdensome” and effectively stating that Title IX, an educational statute that prohibits discrimination based on gender at any institution receiving federal funds, is inapplicable to NIL.
“There’s a lack of mention of Title IX and lack of mention of gender in the SCORE Act, which is extremely disappointing and leads to a lot of ambiguity as to any protections,” said Dr. Lisa Delpy Neirotti, director of the master’s in sport management program at George Washington University School of Business and an associate professor of sport management.
This is particularly troublesome as college sports is awaiting massive compensation to collegiate athletes who are competing or have competed. This settlement is a result of an antitrust lawsuit, House v. NCAA, which allows direct compensation of collegiate athletes for their NIL. Part of the settlement is a $2.8 billion payment from the NCAA and major athletic conferences. It is anticipated that football and men’s basketball will receive approximately 90 percent of the money.
“This creates a huge disparity based on gender and violates Title IX,” said Shiwali Patel, senior director of safe and inclusive schools for the National Women’s Law Center. “Given that Congress has decided to address NIL compensation for students—essentially in many ways codifying this settlement agreement—it is so important that Congress make clear that Title IX applies here.”
To be clear, this does not apply to individual NIL deals that student-athletes have—be they lucrative deals with a corporation or a sponsored social media post. It relates to monies that come through an institution.
Meyer said there are appeals to the Ninth Circuit with respect to the House settlement, two of which directly deal with gender equity, and Patel said colleges and universities should ensure that the resources they’re putting into marketing and promoting sports are equitable, as this impacts NIL opportunities.
“While NIL payments fall within Title IX’s treatment and benefits laundry list requiring equitable promotion, publicity, marketing and even recruitment, they also fall within Title IX’s requirement of proportionate financial assistance,” Meyer explained. “Moreover, they are captured by the 37 words of Title IX that prohibit sex discrimination in benefits provided.”
Twenty-one members of the Democratic Women’s Caucus have sent a letter to members of Congress connected to the SCORE Act, explaining that a bill to regulate NIL compensation must include adequate protections for women collegiate athletes, and not addressing Title IX is a blaring omission.
Data shows that women are being shortchanged in this new landscape. We wanted to make sure our voice was included in urging Congress to amend the SCORE Act to explicitly protect women athletes.
Hilary Meyer, Athletes Unlimited
The members of Congress outlined their concerns and offered several critical provisions, most notably affirming that Title IX protections fully apply to the NIL revenue sharing framework established under the SCORE Act and clarifying guidance from the House v. NCAA to ensure women athletes receive an equitable share of any compensation or settlements.
Rep. Sydney Kamlager-Dove (D-Calif.), co-chair of the Democratic Women’s Caucus, said at present 90 percent of the distribution related to the House Settlement will be going to football and men’s basketball players, largely considered the big moneymakers, and the remaining 10 percent is to be divided between women’s basketball and all other student-athletes.
“That is as unequal, inequitable, disproportionate and shameful as they come,” Kamlager-Dove said, adding that NIL disparities are heightened for Black women. “We’re asking for critical provisions to be added to the SCORE Act.”
The letter noted: “We strongly urge you to amend the SCORE Act to explicitly protect women athletes, reinforce Title IX’s authority and application to NIL compensation, and provide clear statutory guidance in light of recent court decisions.”
“Data shows that women are being shortchanged in this new landscape,” said Hilary Meyer, chief impact and athlete engagement officer of Athletes Unlimited (AU), one of seven organizations that endorsed the letter. “We wanted to make sure our voice was included in urging Congress to amend the SCORE Act to explicitly protect women athletes.”
Kassandra Ramsey, an attorney and president of The Drake Group, which works to educate Congress and higher education about critical issues in intercollegiate athletics, said, “I do think that Title IX applies to NIL anytime that the school has a close relationship with an NIL collective or, in this case, as the schools are now able to engage in revenue sharing with the athletes.”
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Bob Chesney was hired at UCLA at the beginning of December, with the official announcement released Dec. 6th.
He spent two whirlwind days — Dec. 8th-10th — in Westwood for his introductory press conference and a few other media moments.
He then spent most of his time back in Harrisonburg, Virginia, preparing his James Madison team to face Oregon in the first round of the College Football Playoffs.
On Saturday, the Dukes lost, valiantly, to Oregon, 51–34. That ended the JMU season and Chesney’s coaching tenure there.
And the Bob Chesney era at UCLA begins.
Of course, the coach was doing UCLA-related things for the past three weeks, but now he’ll be fully focused and engaged as UCLA’s new coach.
What to do, what to do?
One of college football’s greatest rivalry games is set to come to an abrupt end as it was about to celebrate its 100th anniversary.
The annual Notre Dame vs. USC football rivalry game is no more after the schools failed to reach an agreement on future matchups, ending one of college football’s most recognizable traditions, according to Yahoo Sports’ Ross Dellenger.
Representatives from both schools had been involved in negotiations to preserve the rivalry over the last several months, but could not agree on terms going forward, at least temporarily ending a football series that had been ongoing since 1926.
Gone, but not for good?
Yes, there is some hope that we could see USC and Notre Dame on the same field in the future.
Administrators from both schools did reach an agreement to resurrect the series as soon as the 2030 season, according to the report.
Until now, just a world war and a global pandemic had prevented Notre Dame and USC from playing each other every season, but now the pressures of the modern college football season, and its postseason format, appear to have played a role.
Whose fault is this?
Concerns about scheduling and how the game would affect College Football Playoff positioning were the decisive factors in bringing an end to the rivalry, according to the report.
Most of that concern seemed to arise from the USC side of the equation, which felt that certain precedents established by the selection committee in punishing teams for losses put the program in a disadvantageous position.
USC hinted this would come
USC head coach Lincoln Riley signaled as much when speaking on the future of the rivalry last year.
“There [have] been a lot of teams that sacrifice rivalry games,” Riley told reporters at Big Ten Media Days last summer.
“As we get into this playoff structure, and if it changes or not, we get into this new conference, we’re going to learn some about this as we go and what the right and best track is to winning a national championship, that’s going to evolve.”
Still, even amid those comments, reps from USC signaled a desire to keep the Notre Dame rivalry, and Fighting Irish head coach Marcus Freeman was adamant on keeping the matchup, too, reflecting the position of his school.
Instead, Notre Dame is poised to finalize a home-and-home series with BYU over the next two seasons that will take the place of USC on its schedule, according to the Yahoo report.
We saw this coming
A recent Sports Illustrated report indicated that USC was hesitant to pledge itself to a long-term agreement with Notre Dame, citing concerns over the future of the College Football Playoff format and the Trojans’ existing schedule and travel demands.
“I want to play USC every year because I think it’s great for college football, that rivalry, USC-Notre Dame,” Marcus Freeman said.
“Before I even got to Notre Dame, everybody watched that game. Everybody remembers moments from that game that just stick out in their mind.”
Another college football tradition bites the dust
Losing a historic rivalry of this pedigree would be another stark reminder of the very strict conditions that schools have to work in in a new environment where playoff selection, and appeasing the College Football Playoff committee, is king.
Known as the greatest intersectional rivalry in college football, USC and Notre Dame have met almost every year since 1926, with World War II and the Covid pandemic being the only exceptions.
Now, to that list of historical anomalies, the very format of modern college football itself could be the decisive factor that puts this great rivalry on the shelf.
(Yahoo)
Read more from College Football HQ
The Oregon Ducks are coming off of a 51-34 win over the James Madison Duke at Autzen Stadium on Saturday in the first round of the College Football Playoff.
The Ducks now advance to face the No. 4 Texas Tech Red Raiders in the CFP Quarterfinals at the Orange Bowl in Miami, FL. on Jan. 1, but two more members of the Oregon secondary won’t be in attendance.
Per reports from On3’s Hayes Fawcett, Oregon cornerback Sione Laulea is entering the portal and won’t be with the team for the rest of the CFP. Joining him in the portal will be Oregon safety Kingston Lopa, who will have three years of eligibility left. He also won’t be with the Ducks during what hopes to be a run to the National Championship.
Laulea, who arrived to Eugene before the 2024 season, was the top JUCO cornerback prospect out of San Mateo College headed into his first year at Oregon.
Sione Laulea Chose Oregon for Development
He told the media before this season that he chose the Ducks because he thought it was the best fit for him from a developmental standpoint.
“I transferred from junior college, and the biggest fit for me was just development, because I feel like I used two years, so with two years left in eligibility, I feel like I had to make the most out of my two years,” he said. “So the place that was going to develop me the most and where I fit most in the scheme, and I felt like this was a place, especially with the coaching staff, with Tosh (Lupoi) being such an aggressive caller, and (Chris Hampton) as a secondary coach.”
“I feel like it’s been great,” he continued. “As you guys know, there’s not a lot of experience in our back end, specifically the corner room, but there’s some dogs either way, whether we touch the field or not. You can see it clearly in practice that everyone’s making plays on the ball, and it’s pretty much neck and neck.”
MORE: Three Biggest Takeaways From Oregon’s Playoff Win Over James Madison
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However, things never quite worked out for Laulea. He appeared in 10 games with Oregon while posting just 10 total tackles (five solo), three pass breakups and one pick. His only interception as a Duck came in the 38-9 win over No. 20 Illinois last season.
As for Lopa, he arrived to Oregon as a four-star prospect in the 2024 recruiting class out of Grant Union in Sacramento, CA.
He received some notable praise from Oregon head coach Dan Lanning during the spring.
“It’s just what he does every day in practice. You know, the part that we get to see, and Kingston to be an unbelievable player for us. You know, he’s had a really good spring so far. But you know, he earned those moments by what he did in practice,” Lanning said.
Lopa appeared in 13 games this season while posting 12 total tackles and one pass breakup.
Florida wide receiver Naeshaun Montgomery is planning to enter the NCAA Transfer Portal, On3 has learned. He caught three passes for 26 yards in 2025.
Montgomery played high school football at Miami Central (West Palm Beach, FL), where he was a four-star prospect. He was the No. 262 overall recruit in the 2025 cycle, according to the Rivals Industry Ranking, a weighted algorithm that complies all major recruiting media services.
He had a bunch of different premier programs interested in his services as a recruit. We’ll see who comes calling this time around for the wide receiver.
To keep up with the latest players on the move, check out On3’s Transfer Portal wire. The On3 Transfer Portal Instagram account and Twitter account are excellent resources to stay up to date with the latest moves.
More on Naeshaun Montgomery, NCAA Transfer Portal
Meanwhile, the NCAA Division I Administrative Committee passed dates for the one-time-only college football transfer portal back earlier in October. As it stands, the 2025-26 college football transfer portal will last 15 days. It’ll span Jan. 2 to Jan. 16, the NCAA announced.
Moving forward, the entire Division I football notification of transfer windows is slated for Jan 2-16. As has been the previous standard, athletes on College Football Playoff teams still playing would have 5 days beginning the day after their team’s final game to enter the transfer portal.
Additionally, players have 15 days to enter the portal, but they’re not under a deadline to commit when they enter. Traditionally, the deadline for committing is how late a school can enroll a player through admissions.
One caveat is that if a head coach is fired, the transfer portal will not open for players immediately. The NCAA revealed that moving forward, players will only have 15 days to enter the portal after a coaching change, instead of the former allocation of 30 days. Players will also have to wait five days after a new coach is hired or announced.
Finally, graduate transfers also cannot enter the transfer portal until Jan. 2 with the new one-time-only portal window. All these new guidelines are bound to shake things up, but the transfer portal will still remain as interesting and entertaining as ever.
Dec. 22, 2025, 5:00 a.m. ET
- Some Tennessee football players are expected to negotiate for higher NIL pay after strong performances in the 2025 season.
- Since July, schools can directly pay athletes through revenue sharing, in addition to third-party NIL deals.
- Players who have likely increased their value include DeSean Bishop, Braylon Staley, and several standout freshmen.
- NIL negotiations have become a regular part of the college football calendar, influencing player decisions on transfers and the NFL draft.
Some Tennessee football players will negotiate a raise in NIL pay after overperforming in the 2025 season.
Those discussions have become part of the college football calendar in this era of frequent player movement, and money is a driving force in big decisions.
Negotiations likely started long before No. 23 Tennessee (8-4) plays Illinois (8-4) in the Music City Bowl on Dec. 30 (5:30 p.m. ET, ESPN). And they’ll continue when the transfer portal opens on Jan. 2.
The top players with eligibility remaining consider declaring for the 2026 NFL Draft. Some players consider testing the transfer market by entering the portal. And overperforming players hope to cash in with a pay raise from their school.
Since July, schools have been allowed to pay athletes directly with revenue shares, essentially a royalty for use of their name, image and likeness. Players can earn additional money in third-party NIL pay from collectives, corporations and business owners.
Some players get raises. Other players get pay cuts.
Schools pay players directly under a salary cap of sorts. The payroll works out to about $13.5 million for each college football team, or approximately $170,000 per scholarship player. Those distributions and payroll strategies vary between teams.
And third-party NIL pay can double the earnings of the best players.
None of that payroll information is available to the public, which means it’s impossible to know whether a player is overpaid, underpaid or fairly paid. But it’s reasonable to believe their pay corresponds to their projected level of play.
And if they exceed those expectations, a raise is in order. With that being said, let’s take an educated guess at which players have increased their value.
DeSean Bishop
No Tennessee player has increased his value over the past year as much as running back DeSean Bishop. In January, the former Karns High standout was promoted from walk-on to scholarship player. That likely didn’t come with a big NIL payday because he wasn’t even a starter yet.
But Bishop earned that scholarship, and then some, in the 2025 season. He was named All-SEC second team after rushing for 983 yards and 14 TDs in the regular season. If Bishop wasn’t paid NIL this season, he certainly will next season. And if he was paid this season, it likely didn’t align with an all-conference season.
Braylon Staley
Braylon Staley showed promise heading into the 2025 season, but he was unproven. That quickly changed when he played well in UT’s biggest games and earned SEC Freshman of the Year with 64 receptions, 806 yards and six TDs.
UT may have already paid Staley a solid NIL amount. After all, he was a four-star recruit and top 100 player coming out of high school. But it’s doubtful that Staley was paid like one of the SEC’s top receivers, which he clearly now is.
Wendell Moe
This one is debatable, but leverage could come into play. Wendell Moe was a solid pick-up in the portal in 2025, but he turned into an AP All-SEC performer.
It’s difficult to predict how much UT paid Moe in the 2025 season without knowing the transfer market for his position. If he was coveted by multiple teams, Moe may have been paid well and simply played to that level.
But now Moe has proven to be a good SEC offensive lineman and potential NFL draft prospect. That could land him at least a moderate NIL raise to return in 2026.
Jesse Perry
In the 2024 class, offensive lineman Jesse Perry was rated fifth among five offensive linemen signed by Tennessee, according to 247Sports Composite. He was a three-star recruit.
NIL pay doesn’t always correspond to recruit ratings. But Perry’s moderate grades indicate that he had to prove his value on the field before earning a notable NIL check.
Perry did that in the 2025 season. He started 11 games, including seven at right tackle and four at right guard, and earned Freshman All-America honors.
Granted, his future NIL pay will depend on whether he’s a surefire starter or a versatile backup, but Perry is certainly in a stronger position than a year ago.
Ty Redmond
Like Perry, cornerback Ty Redmond probably entered the 2025 season with a low NIL value and had to prove himself. In the 2025 class, Redmond was rated fourth among five defensive backs signed by Tennessee, according to 247Sports Composite. He was a three-star recruit.
But Redmond, after some early growing pains, turned into a promising young cornerback. He was an All-SEC third-team selection and Freshman All-SEC performer. He tied for the SEC lead with 13 passes defended and led the Vols with three interceptions.
Regardless of what Redmond earned in 2025, he is in a stronger position after his freshman season.
Jordan Ross
This one is more speculative than the rest on this list. After all, edge rusher Jordan Ross was a five-star signee in the 2024 class, so he may already command high pay in NIL money based on his recruit rating.
That being said, Ross is on this list because of his play, his position and his perceived essential status in new defensive coordinator Jim Knowles’ defensive scheme. Knowles values edge rushers, and Ross is UT’s most dynamic.
Before being slowed by injuries, Ross showed flashes as a playmaker in the mold of former UT edge rushers Byron Young, James Pearce and Joshua Josephs. He had three tackles-for-loss, 1.5 sacks, six quarterback hurries, one fumble recovery and one forced fumble.
Adam Sparks is the Tennessee football beat reporter. Emailadam.sparks@knoxnews.com. X, formerly known as Twitter@AdamSparks. Support strong local journalism by subscribing at knoxnews.com/subscribe.
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The No. 10 seed Miami Hurricanes defeated the No. 7 Texas A&M Aggies 10-3 in the first round of the College Football Playoff. It was a defensive battle, ultimately decided by a late fourth-quarter score and red-zone interception by Miami.
With the score tied at 3 and 1 minute, 44 seconds left in the game, Hurricanes wide receiver Malachi Toney scored on an 11-yard touchdown pass thrown by quarterback Carson Beck.
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Up next for the Hurricanes is a Goodyear Cotton Bowl Classic matchup against the No. 2 Ohio State Buckeyes. It’s an uphill battle, as ESPN’s matchup predictor gives the Hurricanes a 29.5% chance of winning.
Miami Hurricanes wide receiver Malachi Toney (10).© Robert Myers-Imagn Images
Before his heroic performance, though, the wide receiver revealed an exciting Name, Image and Likeness (NIL) update. In a joint Instagram post, Toney revealed a new NIL partnership with Hellstar, a popular clothing brand that has a sports training component.
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“We are so proud to announce our first Hellstar Sports College Athlete NIL signing – Malachi Toney🌟.,” the post caption read. “We had the privilege to coach @malitoney10 while he was apart of our high school 7 on 7 program, so now seeing him shine on the collegiate level we couldn’t be more proud.”
Toney’s On3 NIL valuation of $878,000 is the 12th-highest among college football wide receivers. Among players on Miami, it’s the fourth-highest, behind quarterback Carson Beck ($3.1 million), EDGE Rueben Bain Jr. ($1.2 million) and offensive tackle Francis Mauigoa ($1.1 million).
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Through 14 games, Toney has been a major contributor to Miami’s success. He leads the team in receptions (89), yards (992) and touchdowns (eight).
With an exciting NIL opportunity under his belt, he and Miami look to stay hot against Ohio State. Kickoff is Dec. 31 at 7:30 p.m. ET at AT&T Stadium, airing on ESPN and streaming on the ESPN app.
Related: Texas Receives Clear Message From Nation’s No. 2 WR Amid Intense Recruiting Battle
This story was originally published by Athlon Sports on Dec 21, 2025, where it first appeared in the College Football section. Add Athlon Sports as a Preferred Source by clicking here.
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