The Maple Leafs are prepared to fight even the NHL to defend their market.

A group claiming to have some $1 billion in private assets is set to announce Friday that it has a "vision" for a National Hockey League expansion team for Toronto.

Nice gesture and sure to grab media attention, but unless it is the Toronto Maple Leafs parent company, Maple Leaf Sports and Entertainment, or gets permission from MLSE, they should expect a court fight.

Sportsnet.ca has learned that the Leafs have no intention of ceding what they believe are their territorial rights and are prepared to go to court to defend them, whether it is expansion into their market or the bid by Research in Motion co-founder Jim Balsillie to relocate the Phoenix Coyotes to Southern Ontario.

That fight would likely include a battle with the National Hockey League if it were to cut a deal to allow either or any group in without the Leafs' permission.

"We've been told that the Leafs have made their feelings known to the league," a source with knowledge of the proceedings told sportsnet.ca. "It's our understanding that no matter who is behind this group the Leafs have no intention of allowing a second team into their marketplace and that they, not the National Hockey League, have the final say in this matter."

That would set the stage for a lawsuit of massive proportions against the league and its member teams. It would also set the Leafs against the NHL and what it perceives to be its right to determine where franchises go.

"(The Leafs) will sue the league if it attempts to bring a team to the marketplace without their permission and they will sue each of the individual member teams should any one of them bring a team to the marketplace to play that team without their permission. They believe they have that right under the NHL constitution," the source said.

The Leafs have steadfastly refused all comment about another team in their market and commissioner Gary Bettman, though at times claiming he has the right to do that, has steadfastly deflected all questions on what the Leafs would do by stating "you would have to ask them."

Attempts to reach the Leafs for comment were unsuccessful.

According to the source, the league is aware of the threat by the Leafs as is the Balsillie camp, which may bring the issue up in the next court proceeding in Phoenix. Balsillie wants to relocate the Phoenix Coyotes in Hamilton, Ont., an area the Leafs claim is within their territorial rights zone. If Balsillie is successful in securing the franchise it's likely he will then challenge the Leafs in court.

"This is all about the Leafs," the source said, "and the Leafs are saying it (relocation and/or expansion) is not OK with them at any price."

The source also said that the Leafs and the NHL may be at odds over who has the right to approve an expansion or relocation.

Bettman has said he has control of the issue via a clause in the constitution that gives him the power to act in the best interest of the league.

That would be Article VI in the league constitution under the heading Power and Duties, paragraph 6.3 (D) which reads: Interpretation of League Rules. "The Commissioner shall have the authority to interpret, and from time to time establish policies and procedures regarding, the provisions of the Constitution, the By-Laws and League rules and resolutions, and their application and enforcement. Any determination made by the Commissioner with respect to any such matter shall be final and binding and shall not be subject to any review."

That's an argument Bettman allegedly made to Canada's competition committee regarding his powers in the matter and it was accepted by the committee.

However, the issue of an individual club exercising an individual veto has never come up even though the Leafs maintain they have that right.

It's complicated, but consider:

On other occasions Bettman has cited Article IV titled "Territorial Rights. In paragraph 4.2 "Territorial Rights of the League" it states: The League shall have exclusive control of the playing of hockey games by Member Clubs in the home territory of each member, subject to the rights hereinafter granted to members. The members shall have the right to and agree to operate professional hockey clubs and play the League schedule in their respective cities or boroughs as indicated opposite their signatures hereto. No member shall transfer its franchise to a different city or borough. No additional cities or boroughs shall be added to the League circuit without the consent of three-fourths of all the members of the League. Any admissions of new members with franchises to operate in any additional cities or boroughs shall be subject to the provisions of Section 4.3.

That three-fourths approval argument is well known, but the last two lines of section 4.3 seem to give the Leafs a play. According to the source, the Leafs have a legal opinion that their argument has merit and trumps Bettman's argument to the competition committee.

In section 4.3, "Territorial Rights of Members", the last two lines read: "No other member shall be permitted to play games (except regularly scheduled League games with the home club) in the home territory of a member without the latter member's consent. No franchise shall be granted for a home territory within the home territory of a member without the written consent of such member."

They two sentences appear to support the 4.2 rule regarding rights "hereinafter granted to members." In essence the Leafs believe that gives them the final say whether a team sets up in their territory and they plan to say no. Should Bettman go against them, they will sue. Should other member teams show up to play a team other than the Leafs in the Leafs territory, they will sue.

In addition, the Leafs are banking on Paragraph 12.1 entitled "Unanimous Consent" which states: "Any provision of this Constitution may be amended at any meeting by unanimous consent of all members of the League present and voting. Article III, Article IV, Article IX and this Article XII shall not be amended except by unanimous consent of all members of the League present and voting. Any amendment of Article III, Article IV, Article IX or this Article XII shall be evidenced by an instrument in writing signed by all members of the League."

Since the Leafs would base their right to say no on Article IV, Section 4.3 and since they would likely never vote in writing or otherwise to give that right away, they would argue they have a basis to sue should the NHL or even the courts allow another franchise to enter its claimed territory.

They Leafs may not admit it, but if the battle is to be joined - via expansion, relocation or the whim of the commissioner of the National Hockey League - the Leafs intend to have a legal say in how it all plays out.

Even if it means taking on the commissioner and the brotherhood of members that make up the National Hockey League.