A Comparative Analysis of Name and Likeness Rights in the United States and England

This comment will initially examine English law regarding appropriation, using as a point of departure the early professional cases. It will then discuss the contemporary standard applied in modern actions under the theory of passing off, tracing the development of the theory. Thirdly, the right of privacy will be examined from the American perspective. The right of publicity, the fourth topic, is derived from the right of privacy. Finally, after a brief look at the extrajudicial source of the rules utilized by the British Advertising Industry, the comment will conclude with a discussion of the author\u27s proposals for future legislation