IN THE MATTER OF A SALARY ARBITRATION BETWEEN
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IN THE MATTER OF A SALARY ARBITRATION
BETWEEN:
LARS ELLER
-AND-
THE MONTREAL CANADIENS
BEFORE: NATIONAL ACADEMY OF ARBITRATORS
BRIEF IN SUPPORT OF A COMPENSATION REQUEST FOR LARS ELLER
Team 15, Counsel and Agent
Table of Contents
I. INTRODUCTION…………………………………………………….…....…………1
II. OVERALL PERFORMANCE OF MR. ELLER……..…………………….…….......2
III. NUMBER OF GAMES PLAYED AND INJURY HISTORY………….……….…...3
IV. CAREER TO PLATFORM STATISTICS ...………………………….………....….. 3
V. PLATFORM SEASON STATISTICS………...………………………...……………4
VI. OVERALL CONTRIBUTION TO CLUB.…………….…………………..………...4
VII. COMPARABLE PLAYERS…...…………………………………………..…………4
VIII. CONCLUSION…………….…………….……………………………………………5
I. INTRODUCTION
This brief will provide admissible evidence pursuant to the terms of the Collective
Bargaining Agreement (“CBA”),1 between the National Hockey League (“NHL”) and the
National Hockey League Players Association (“NHLPA”), to assist in quantifying Lars Eller’s
(“Mr. Eller” or “the Player”) value to the Montreal Canadiens (“the Canadiens” or “the Club”)
for the 2014-2015 NHL season.
It is recognized that Mr. Eller is eligible for salary arbitration to determine his compensation
with respect to the 2014-2015 season. To that end, the Player has exercised this option and can
only be compared to forwards with the same arbitration rights.
This brief will also provide a framework that is capable of awarding appropriate value to Mr.
Eller’s offensive contributions to the Canadiens. In awarding value to a forward, such as Mr.
Eller, NHL experience, points per game (“Pts/G) and two way ability statistics such as hits carry
the most weight in appreciating a player’s worth to their Club. Following this, Mr. Eller’s
valuation will consider: overall performance, number of games played, injury history, length of
service, and his overall contributions to the Canadiens as well as his history outside of Montreal.
Mr. Eller will also be objectively compared against two forwards who were arbitration eligible
within the last three years by statistical filters with respect to their career-to-platform and
platform-seasons to validate his positioning in the NHL marketplace. The salaries of the
comparable forwards will frame the narrow range to assign Mr. Eller’s value.
On behalf of the Player, Mr. Eller, we respectfully submit that $3,650,000 is an accurate and
equitable assessment of his value to the Canadiens for the 2014-2015 season.
1
NHL Collective Bargaining Agreement, between the National Hockey League and the National Hockey League Players
Association, September 16, 2012- September 15, 2022, s. 12.1(a)-(c), p 57.
1
II. OVERALL ASSESSMENT OF THE PLAYER
Mr. Eller is a 26 year-old, left-handed utility center from Rodovre, Denmark. Mr. Eller is
6’2”, 215 lbs., as of the beginning of the 2013-2014 NHL season. In the 2007 NHL Entry Draft
(“Draft”) the St Louis Blues (“the Blues”) selected Mr. Eller, in the first round, 13th overall.2
The Player’s high selection in the Entry Draft is the partial result of the high value teams place
on his style of play as well as his size and success on the Denmark junior team.
Mr. Eller is a prototypical power forward with a combination of power, size and skill that
allows him to consistently create scoring situations. Mr. Eller remained with the Blues until June
17th, 2010 when the Canadiens acquired him via trade, sending major components back to the
Blues, which included a starting goalie in Jaraslov Halak.3
Aside from his NHL experience, Mr. Eller was selected to represent Team Denmark at the
World Hockey Championships in 2008, 2010, and 2012. During these tournaments Mr. Eller
performed quite well considering the talent pool of the teams in this tournament, scoring 5 goals
and registering 7 assists in 20 games played.4
III. NUMBER OF GAMES PLAYED AND INJURY HISTORY
Mr. Eller has played five seasons in the NHL accumulating 286 games, with 279 with the
Canadiens.5 During the 2009-10 season, Mr. Eller split his playing time between the Blues and
their American Hockey League (“AHL”) affiliate and had the third highest points for rookies in
the AHL that season and was chosen to the All-Rookie Team.
Mr. Eller’s only injury came off a dangerous play by Eric Gryba, in which he suffered
concussion and facial fracture during the 2012-2013 playoffs. However, he has since had no
2
http://www.nhl.com/ice/player.htm?id=8474189&view=splits&season=20132014&gameType=3
3
http://www.tsn.ca/nhl/story/?id=324934
4
http://www.hockeydb.com/ihdb/stats/pdisplay.php?pid=105385
5
Supra Note 2
2
complaints and was given a clear bill of health.6 Eller did not change his physical style of game
as indicated by his consistent hits/game ratio being over 1.5. It is the Player’s submission that
playing on a team without debilitating injury increases the Player’s worth to a team as it builds
chemistry and allows for coaches to rely on him. Mr. Eller offers the Canadiens an offensive
pillar who can be used in many situations, while adding to the physical dynamics of the game.
IV. CAREER-TO-PLATFORM STATISTICS
Table
1:
Eller
Career
Statistics
Season Team GP G A P TOI Blk PIM PPP GWG S Hits FO%
09-10 Blues 7 2 0 9 10:49 1 4 1 0 8 8 47.4
10-11 Club 77 7 10 17 11:08 22 48 0 2 79 85 42.4
Playoffs Club 7 0 2 2 13:04 5 4 0 0 11 18 43.1
11-12 Club 79 16 12 28 15:18 55 66 3 2 72 72 46.6
12-13 Club 46 8 22 30 14:49 33 45 5 1 84 86 49.3
13-14 Club 77 12 14 26 15:57 58 22 3 3 137 130 53.2
Playoffs Club 17 5 8 13 16:27 8 18 0 1 23 30 43.2
* Indicates Platform Season7
Mr. Eller’s comprehensive analysis will use both, career-to-platform statistics and his
platform-season statistics to determine the most appropriate positioning for Mr. Eller’s worth in
the current marketplace. Mr. Eller recorded career highs in the 2012-2013 shortened season with
8 goals, 22 assists for a total of 30 points, which equates to 0.65 Pts/G in 46 games played.8
While he failed to surpass this Pts/G ratio in his current platform season he has remained
consistent in goal scoring ability. It is Mr. Eller’s ability to produce in the playoffs that
differentiates his play. In the Canadiens 2013-14 playoff run Mr. Eller was second on his team in
points with 0.76 Pts/G, which included 5 goals and 7 assists.
Mr. Eller’s career scoring statistics coupled with his top hitting and blocked shot numbers
amongst Canadiens forwards suggest that he is a proven and balanced two way forward. Mr.
6
http://www.nhl.com/ice/news.htm?id=680274
7
Supra
note
2.
8
Supra note 2.
3
Eller also has strong faceoff statics as seen in table one. We put forward that Mr. Eller’s true
value to the team is his ability to step up in big games as indicated by his playoff performance
and timely goals.
V. PLATFORM-SEASON STATISTICS
Mr. Eller played 77 regular season games as well as 17 playoff games in his platform-season,
demonstrating both scoring ability and defensive capacity. Mr. Eller’s career-to-platform
statistics support the possibility of an increase in Pts/G totals in the upcoming seasons. To this
end, Mr. Eller’s platform-season can be relied upon to measure the valuable impact his offense
has on the Canadiens success, particularly as the club continues to push for a Stanley Cup. The
Club also relies on his ability to push the pace with hits, while being defensively minded, as he
has the most blocked shots amongst Canadiens forwards. The Club has also become more
comfortable with Mr. Eller on the ice as indicated with his increased TOI during playoff games,
and he has consistently improved his faceoff taking skills.
V. OVERALL CONTRIBUTION TO THE CLUB
While players are paid for their season performance, it is highly valuable for a player to be
able to increase their output during the playoffs. Mr. Eller’s TOI has been consistently rising
over his career and the playoffs saw his highest TOI during his career. Mr. Eller is not known for
being a natural scorer, but his playoff performance was second only to PK Suban on the
Canadiens. The Candiens’ reliance on Mr. Eller’s two way game, and ability to dictate play
against the elite in the league is demonstrated by his Relative Corsi quality of competition of
0.224.9 Considering the value of a true power forward to the Canadiens, and the coaching staffs
increasing confidence in Mr. Eller, it is safe to assume that he will continue his trajectory as a
9
BehindTheNet
http://www.behindthenet.ca/nhl_statistics.php?ds=30&f1=2013_s&f2=5v5&f5=MTL&c=0+1+3+5+4+6+7+8+13+14+29+
30+32+33+34+45+46+63+67
4
staple in the Canadiens franchise. The Montreal Canadiens are now posturing for a Stanley cup
push and while Mr. Eller’s play is valuable in the season, it is his ability to increase production in
big games that differentiates him and makes him a very valuable commodity.
VI. COMPARABLE PLAYERS
Mr. Eller is an elite power forward in the NHL who consistently creates scoring
opportunities, and is relied upon for the penalty kill due to his size, speed and skill. The selection
of objective search filters allows for a more comprehensive comparison of a forward’s offensive
characteristics. The objective filters that are employed are based both on, career-to-platform
statistics and platform-season statistics which are as follows: points per game (“pts/G”) +/-15%,
points per game (“Pts/G”) +/-20%, shooting percentage (“S%”) +/-10%, and time-on-ice (“TOI”)
+/- 3:00/G and playoff performance during playoffs in their platform season in these categories
as well. The players chosen with these filters are Brandon Sutter and Patrick Berglund.
Table 2: Statistics for Comparable Players10
Player GP G A Pts Pts/G PIM TOI/G Hits S S% Fo% BLK
Lars 77 12 14 26 .34 68 15:57 130 97 8.8 53.2 125
Eller
Platform 17 5 8 13 .77 18 16:27 30 23 21.7 43.2 1
Playoff
NHL 288 45 58 103 .36 235 ===== 381
441 10.2 45.3 15
Totals:
Brandon 81 13 13 26 .32 36 15:46 69 144 9.0 47.7 40
Sutter
Platform 13 5 2 7 .54 2 15:53 13 28 17.8 55 1
Playoff
NHL 415 77 75 152 0.37 80 ===== 69 768 10.0 47.5 12
Totals
Patrick 78 14 18 32 0.41 38 16:10 88 144 9.7 47.6 30
Berglund
Playoff 4 0 0 0 0 0 15:05 10 9 0 42.1 0
Platform
NHL 436 106 114 220 0.50 198 ===== 482
854 12.2 46.5 4
Totals
10 Supra note 2.
5
Table 3: Contract Data11
Player 2013-2014 Cap Hit Date Signed
Brandon Sutter $3,300,000 August 5, 2014
Lars Eller $3,650,000 Pending Arbitration
Patrick Bergland $3,700,000 June 26, 2014
a. Mr. Eller compared to Brandon Sutter
Brandon Sutter is a 25 year-old, right-handed Centre from Huntington, New York who will turn
26 in February 2015. Mr. Sutter is 6’3”, 190lbs., as of the 2013-2014 NHL season. In the 2007
NHL Entry Draft the Carolina Hurricanes (“the Hurricanes”) selected Mr. Sutter, in the first
round, 11th overall. The Player’s high selection in the Entry Draft is the partial result of his size
and two-way ability, similar to that of Mr. Eller.
While Mr. Eller does not have the same amount of experience as Mr. Sutter, Mr. Eller’s
similar season statistics and high playoff production while playing less games help make the two
players comparable. Mr. Sutter’s salary is lower than what is being asked for by Mr. Eller. This
is because Mr. Sutter’s platform season and platform playoff performance is less than that of Mr.
Eller. Further, Mr. Eller, is a much more aggressive player as evidenced by his hits block shots,
and penalty minutes. While Mr. Sutter’s playoff TOI dropped, Mr. Eller’s raised substantially
during the playoffs. This is because Mr. Eller’s playoff performance saw an increase in points, a
higher winning percentage on the circle while maintaining his physical play. Mr. Eller’s shot
accuracy also increased dramatically in the playoffs, indicating that during high pressure
moments with more ice time he was able to chose his shot selection more carefully.
It should be noted that Mr. Sutter’s current salary was awarded on a career to platform,
which saw a higher pts/G total than his platform season. This decrease in ability to produce
should serve as model of how to appropriately compensate Mr. Eller for consistent Pts/G in the
11
Capgeek online: .
6
2013-2014 platform season and a large increase in playoff performance.
Mr. Eller and Mr. Sutter are comparable players in terms of statistical contributions, and
style-of-play over career to platform. Mr. Sutter represents an appropriate marker for which Mr.
Eller’s value should not drop below. This is because while producing the same amount of pts/G
as Mr. Sutter, Mr. Eller also blocks 3 times as many shots and hits nearly twice as much while
being the same size. It is the Player’s position Mr. Eller’s value is worth more than that of Mr.
Sutter for these reasons.
b. Mr. Eller compared to Mr. Berglund
Patrick Berglund and Mr. Eller are the most appropriate comparable in terms of their
contributions to their Clubs during their platform-seasons and throughout their career-to-platform
performances. Mr. Berglund is a 26 year-old, left-handed winger from Vasteras, Sweden. Similar
to Mr. Eller, Mr. Berglund was drafted in the 1st round 25th overall in the 2006 Entry Draft by the
St. Louis Blues. Mr. Berglund has been with the Blues since drafted.
In his platform season, Mr. Berglund recorded 0.48 Pts/G in 78 games played. In
comparison, Mr. Eller had recorded slightly less by scoring 0.34 Pts/over 77 games.12 Once
again, Mr. Eller’s ability in the playoff to produce was much higher. The Blues lost in 6 games
during their playoff run, and Mr. Berglund had an undisclosed injury.13 Mr. Berglund’s TOI was
also decreased during these playoffs. While Mr. Berglund has had more success in seasons than
that of Mr. Eller, Mr. Eller’s two-way game demonstrates his value. Further, Mr. Eller’s ability
to produce in big games such as the playoffs has led the coaches to entrust him with heavier
minutes.
During Mr. Berglund career, in 415 games played, he has scored an average 0.50 Pts/G. Mr.
12
Supra note 2.
13
http://www.rotowire.com/hockey/player.htm?id=2572
7
Eller, in fewer games, has recorded an average of 0.36 points per game.14 While Mr. Berglund
has played more games, and had more ice time his dip in production during his platform year and
playoffs are issues that are not present with Mr. Eller. Further, Mr. Eller also uses his body more
than Mr. Berglund as indicated by hits and blocked shots. Given their similarities, and Mr.
Eller’s increase in production during his platform season, Mr. Berglund is the most appropriate
comparable player, and thus, Mr. Eller deserves a salary in the narrow range of Mr. Berglund’s
Salary of $3,700,000.
VII. CONCLUSION
This brief has assessed Mr. Eller’s value with respect to his overall career performance, NHL
experience and injury history, his overall contributions to the Club and identified two
comparable players to best frame the current market value. The head-to-head comparisons
demonstrate the appropriate selection of comparable players, which frame the current market
value for Mr. Eller. Mr. Eller should be awarded $3,650,000. In consideration of the totality of
Mr. Eller’s contributions leading up to this arbitration, particularly his platform season and
playoff performance, it is respectfully submitted that the compensations request of $3,650,000 be
granted for being an accurate assessment of what Mr. Eller is worth for the 2014-2015 season.
14
Ibid
8
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