The NHL contends Balsillie's effort to purchase the Coyotes out of Chapter 11 bankruptcy and relocate them to Hamilton is a "sham."
"Who owns or controls the team is a distinction without a difference," Balsillie said in a statement Thursday. "The team itself is still bankrupt, voluntarily or not. The owner of the team has a fiduciary obligation towards the creditors."
Balsillie, the co-CEO of BlackBerry maker Research In Motion, has twice tried and failed to buy an NHL team (Pittsburgh and Nashville) and move it to southern Ontario.
He has offered more than $212 million for the Coyotes. He said Thursday his offer, which is conditional on moving the team to souther Ontario, goes the furthest in "satisfying creditors' claims."
The parties will be in court for a bankruptcy hearing Tuesday.
"At the end of the day, this is about the passion Canadians feel for the game of hockey and a chance to provide those fans with the opportunity to support a seventh NHL team," Balsillie said. "That's what this is all about, great hockey fans in a great hockey market."
The NHL says Coyotes majority owner Jerry Moyes gave up the right to place the team into bankruptcy when he received financing from the league last year. The league also contends Moyes has no right to complete a sale conditional on a move to southern Ontario because that territory belongs to the league.
"Any bid for the sale of the Phoenix Coyotes solely for relocation to Ontario is a sham and should be rejected by this court," the league said in Arizona bankruptcy court Wednesday.
The NHL adds that Moyes has not complied with all the rules he agreed to when he bought the Coyotes, and there isn't time for the franchise to be moved before next season.