New York

Brown v. Electronic Arts, Inc. in New York Law

How Brown v. Electronic Arts, Inc. applies in New York: state-specific rules, key cases, and bar exam notes for Intellectual Property.

State Approach

New York recognizes the right of publicity, which protects individuals from unauthorized commercial exploitation of their likeness. The state also balances this right against First Amendment protections, often favoring expressive works.

State Rule
In New York, the right of publicity, as codified in the Civil Rights Law Sections 50 and 51, provides that no person shall use an individual's name, picture, or likeness for advertising or trade purposes without consent.
Significant State Cases

Rogers v. Grimaldi

The Second Circuit held that the use of a person's name in an expressive work is protected unless it is explicitly misleading.

Gordon v. Verizon Communications, Inc.

The court confirmed that artistic relevance is an important factor in determining the applicability of the right of publicity.

Hoffman v. Capital Cities/ABC, Inc.

The court ruled that the use of a celebrity's image in a movie still may violate the right of publicity, depending on the transformative nature of the usage.

Comparison to Federal Law

New York's right of publicity law provides more explicit statutory guidance than the common law approaches often applied in federal courts. While both legal frameworks prioritize the balance between publicity rights and freedom of expression, cases like Brown highlight how New York's structure may afford more protection to individuals.

Bar Exam Note

Understanding the nuances of the right of publicity in New York is key for the bar exam, particularly in intellectual property and tort law sections.

Practice Pointers
  • Evaluate whether the use of a likeness is transformative to apply the right of publicity.
  • Consider both statutory and case law when analyzing publicity rights and First Amendment defenses.
  • Stay updated on recent New York cases as interpretations in this area can evolve.

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