Jimmy and Dee Haslam on Monday threatening legal action via Ohio Revised Code 9.67—more popularly known as the “Art Modell law”—unless the Browns provide “the City or others with the opportunity to purchase the team, as required by law.”

Bibb wrote the Browns have until Jan. 9 to respond or face unspecified legal action. One potential action would be Cleveland petitioning a court for an injunction to stop the NFL franchise from taking relocation-related steps. The Browns could contest that petition and argue the city lacks the legal justification for an injunction.

In October, the Browns sued Cleveland in an Ohio federal court. The lawsuit contends that the Modell Law violates several provisions of the U.S. Constitution and that, even if the law is found to comply with the Constitution, the Browns have followed it.