PHOENIX - Jim Balsillie could be facing a US$100-million fee for the right to move the Phoenix Coyotes to Hamilton, and the question is could it be enough to make the Canadian billionaire walk away from the whole deal.

Balsillie's lawyer Susan Freeman says that's how much she expects an NHL-imposed relocation fee to be and that a figure too high could scuttle the deal.

Bankruptcy judge Redfield T. Baum agrees that the NHL is entitled to a fee and says that figure is crucial to his decision on the fate of the insolvent Coyotes. He wanted to think the matter over before making a decision on how to proceed Wednesday.

During a combative and entertaining court hearing Tuesday in Phoenix, Baum also suggested he may grant the motion to relocate the Coyotes to force the NHL to come up with an relocation fee amount.

The league has not confirmed the US$100-million figure -- the amount was blacked out in court documents -- and deputy commissioner Bill Daly refused to speculate outside the courthouse on how much would be enough.

Balsillie, the co-CEO of BlackBerry-maker Research In Motion, has bid US$212.5 million for the insolvent Coyotes on the condition he move the team to Hamilton -- something the league is against.

But it remains to be seen whether Balsillie be willing to pay the relocation fee in order to get the team to Hamilton.

His lawyer Richard Rodier says their bid for the club includes an option to walk way if a relocation fee is required.

Baum has already tentatively set June 22 as the day the Coyotes could be sold at auction, so the timeline to get the relocation fee issue sorted out is tight.

He said identifying the fee would perhaps cause Balsillie to either accept it or prompt him to walk away, allowing for a solution without having to solve the more complex issues before the court.

NHL lawyers told the court that the league would need time to study what an appropriate relocation fee would be.

"You may be forced to do that on a very expedited basis," Baum said, adding later: "If that means this is over, it might be better for everyone."

NHL commissioner Gary Bettman dodged questions about the issue as he hopped into a waiting limo headed to the airport. Bettman was due to be in Pittsburgh for Game 6 of the Stanley Cup final Tuesday night.

"We're not going to get into the specifics, it's obviously before the courts," said Bettman. "The judge has a lot of facts and legal issues before him and we believe the judge was extremely well informed and my hope is he comes to right conclusion.

Coyotes owner Jerry Moyes and several members of the team's front office were also at the hearing, as was Rodier.

The hearing is the latest step in the back-and-forth wrangling over the team's future since Moyes caught the NHL by surprise and filed for Chapter 11 protection on May 5.

More than 300 documents have been filed with an Arizona bankruptcy court since, making each side's argument in the contentious case.

The NHL contends Balsillie's bid is an attempt to skirt the league's rules on the transfer of ownership and relocation, arguing attempts should first be made to sell the team to a buyer who would keep it in Phoenix, despite over $300 million losses since the franchise moved to the desert from Winnipeg in 1996.

Bettman said in a court filing that four interested parties filed preliminary applications last week with the intent of operating the Coyotes in Arizona.

Among them are Toronto Argonauts owners Howard Sokolowski and David Cynamon, and Chicago White Sox and Bulls owner Jerry Reinsdorf.

While their bids aren't expected to top what Balsillie has on the table, the NHL argues his offer is actually $165 million once the $25 million owed to the league and $22.5 million due to coach and part owner Wayne Gretzky is factored in.

The NHL also believes the Coyotes could be viable where they are under new ownership and with new concessions of about $15 million annually the City of Glendale, home to the team's arena, is apparently willing to make.

Balsillie and Moyes disagree in their briefs, saying the Coyotes have never turned a profit since the former Jets flew south, and that the club would flourish in Hamilton.

They argue that the Coyotes are worth far more if they can be moved rather than kept in Phoenix, offering a greater return for the team's creditors.

Balsillie's lawyers also believe the Coyotes meet all of the NHL's criteria for relocation and that preventing the move would violate antitrust laws.

The City of Glendale is siding with the NHL, arguing that the franchise must honour the 23 years remaining on its lease of Arena. The city spent $183 million to build the arena for the Coyotes.