Entertainment Law Outline 1
- Representing Talent
- A business of intermediaries
- Agents focused on deals, personal mngrs on career development
- Business mngrs (usually CPAs) focus on financial aspect of clients’ careers
- Strong fiduciary obligation to client (ABKCO)
- A lot of malpractice claims filed against enter’mt lawyers
- Attorneys
- Establishing an attorney-client relationship
- Att’ys should not give advice unless prepared to accept responsibility for client’s reliance
- Att’y is part of team of ppl representing a person
- Each type of att’y is differ: book att’y v. music att’y v. acting att’y
- Retention agmt defines expectations
- Att’y has highest level of fiduciary duty under the law
- Duty of Competence
- Legal knowledge, skill, thoroughness + preparation reasonably necessary for representation
- Consultations w/ more experienced counsel highly advisable
- Conflicts of Interest
- Enter’mt business conducive to COI
- Multiple client representation
- MRPC 1.7
- (a) Except as provided in paragraph (b), a lawyer shall not represent a client if the representation involves a concurrent COI. A concurrent COI exists if:
- The representation of one client will be directly adverse to another client; or
- There is a significant risk that the representation of one+ clients will be materially ltd by the lawyer’s responsibilities to another client, a former client or a 3d person or by a personal interest of the lawyer
- (b) Notwithstanding the existence of a concurrent COI under paragraph (a), a lawyer may represent a client if:
- Lawyer reasonably believes he will be able to provide competent + diligent representation to each affected client
- Representation is not prohibited by law
- Representation does not involve assertion of a claim by one client against another client represented by that lawyer in the same litigation or other proceeding before a tribunal &
- Each affected client gives informed consent, confirmed in writing
- Designed to advance & protect confidentiality & undivided loyalty
- Factors for assessing COIs:
- Duration & intimacy of lawyer’s relationship w/ client’s involved
- F(x)s being performed by lawyer
- Likelihood that disagreements will arise
- Likelihood of prejudice to client from conflict
- Key to dealing w/ COI:
- Be super careful
- Go to bar and ask them Qs to see if there is a conflict
- Music lawyer as mngr or agent
- Musicians looks to att’y to get deals for them
- How do they get pd when young musicians don’t have $?
- Bar Ass’ns ltd % payments to personal injury att’ys
- Most all att’ys in music industry get pd on % of deal –usually 5-10%
- Fee still has to be reasonable
- If want to be a mngr & att’y, increase commission to cover legal services, but exclude litigation services as part of the legal services covered in commission
- Special considerations re: lawyer conduct
- Merging the roles of various enter’mt representation
- Lawyers who act as agent/mngr are still subject to states’ codes of PRE to extent any activities involve delivery of legal servs
- Advertising & solicitation- MRPC 7.2 + 7.3
- Compensation for att’y servs & retention agmts
- Customary contingent fee is 5-10% of defined compensation earned by the client
- Sunset provision- get a declining % after expiration of term of retention/contingency fee agmt
- Model rule 1.5 requires hourly & contingent fees to be reasonable
- Criteria for reasonable fee:
- Time & labor required
- Novelty & difficulty of the Qs involved
- Skill requisite to perform the legal service properly
- Fee customarily charged in the locality for similar legal servs
- Amount involved & results obtained
- Experience, reputation & ability of lawyer(s) performing the servs required
- Fixed or contingent fee
- Contingent fee agmts must be:
- In writing
- Signed by client
- State method by which fees are to be determined, % lawyer shall accrue in event of settlement, expenses to be deducted from recovery
- Agents & Personal Mngrs
- Agent is someone who procures employ’mt on behalf of the artist
- CAVEAT: In CA, can be either a mngr or agent, but cannot be both
- Agents want as many clients as possible, mngrs can only handle a few clients at a time
- Union regulation of agents
- Collective bargaining agmts negotiated b/w unions & producers
- Union Franchising System- gives the good housekeeping seal of approval for an agency deal
- Agents regulated by unions through franchising licenses
- Keep licensing of agents from being a sham
- Keep agent % down on deals
- State regulation of agents
- NY & CA
- Agents must be licensed
- CA will accept almost any case that touches CA in some way
- Labor Commission is generally the “state court” that determines whether you violated the law
- Violations:
- Mngr procured employ’mt for artist—even if just once
- LC will declare K b/w mngr & artist null & void ab initio & make mngr give artist back all collected commission
- LC is pro-artist
- Won’t recognize arbitration clause if find K to be null & void
- Minors?
- Certain amount of $ must be put away in trust
- Ct will appt a guardian ad litem for minors going into K deals to protect them from bad deals
- Mgmt Deal Components:
- Commission
- Pd % of artist’s income (15-25%)
- Net v. gross
- Net- cut out expenses artist pd before mngr gets pd % (Artist wants this)
- Records deals: most the $ coming from record pays for the actual recording
- Gross- income before expenses (Mngr wants this)
- Mngr can get portion of getting client a record deal, i.e. finder’s fee
- But if att’y, may not be allowed finder’s fee
- Term
- Generally 3 years, 2 for newer/younger mngr
- Irvine- 5 yrs (Owner of Frontline Mgmt- the most important mgmt co in world; he only works on a handshake deal)
- Way to incentivize—longer term = need to get artist more work
- After Term Income (“sunset” provision)
- $ earned after agmt is over for deals that occurred during mngr’s term
- Makes sure mngr gets pd for everything he worked on
- Expenses
- Dictates what mngr can spend w/o authority & still get reimbursed by artist
- Mngr still has to inform artist of all expenses on a regular basis
- Authority
- Mngrs usually want:
- Power of att’y
- Ability to hire/fire ppl
- Dictates what artist wants mngr to be able to do
- On certain issues, will always need artist’s permission
- Other:
- Arbitration clause
- Fiduciary duties
- Mngrs want reasonable efforts, artists want best efforts
- Cases—This is all CA Law
- Buchwald v. Superior Ct of San Fran (CA 1967)
- Katz signed Jefferson Airplane
- Katz not licensed
- Said he would procure shows for them & receive commission
- All mngr agmts disclaim: I’m not your agent even if I get you a job
- Agmt says supposed to resolve disputes through AAA, instead referred to Labor Commiss’r under Talent Agency Act (TAA)
- TAA K b/w unlicensed agent & artist void
- Agmt b/w Katz + JA for personal rep advisor & mngr
- Does not promise to obtain employ’mt for JA
- JA says verbal promise
- K misrepresented Katz as an agent
- Katz refused to allow them to get own bookings; no payment for bookings they did perform
- TAA remedial statute
- Licensed or not, bound by Artists’ Mngrs Act
- TAA LC empowered to hear disputes re: validity of agent-artist K
- Doctrine of “exhaustion of administrative remedies”
- Must first seek relief from admin body before going to ct
- Holding: LC has original jurisdiction to hear disputes arising under TAA, agmt invalid b/c it did not comply w/ Act
- Issue—form of the transaction (representing to JA that an agent)rather than substance (K saying not an agent) controls!
- Case stands for principle behind power of LC
- Jurisdiction of LC should be interpreted broadly
- Pryor v. Franklin (CA 1982)
- F mng-d P from 1975-1980
- 1981 hearing said K void b/c F acted as unlicensed agent
- F to repay P
- F promise to:
- Procure employ’mt
- Negotiate agmts
- Held out as agent to 3d party
- P’s “sole & exclusive negotiator”
- Holding: “Broadest remedy of restitution”—F solely culpable for all violations of law, P shared no blame or guilt
- K ruled void ab initio b/c F not licensed so F turns over all $ made to P
- Rosenthal: Ct didn’t like Δ & develop draconian rule against Δ
- Rule: Can’t be in room during negotiations
- Barr v. Rothberg (CA 1992)
- Oral agmt for R to represented B
- R induced B to sign written agmt as an agent
- R not licensed
- B was w/ Triad Agency—terminates agmt w/ TA shortly after meeting w/ R
- Prior to 1988-1990, B hired William Morris Agency
- WMA commission on all except ‘Roseanne’ show b/c TA procured that
- R part of renegotiations, B received more as part of success of show
- Holding: R acted as a personal mngr during renegotiations, which was a joint effort, relief to B denied
- Agent must find engaged in procuring, offering, promising or attempting to procure employ’mt or engagements
- New Rule: Can be in negotiation room as long as not the one procuring the work
- Statutory exception: if agent asks mngr to lead negotiations, does not mean mngr procured work
- Center of Gravity test:
- Against the mngr
- Must look at entire business of representation
- Bright Line test: right to void Ks that secured any type of work
- Park v. Deftones (CA 1999)
- Δ terminates personal mngr K w/ w/o paying ’s commissions
- got deal w/ Maverick, whose agent, Gary Oscary, interfered w/ & Δ’s K-ual relationship
- sued for commission, Δ countersued saying mngr procured work for them
- said that showcase was an incidental booking in order for the band to get paying work
- Holding: K void b/w & Δ b/c secured performance engagements for Δ w/o being licensed as a talent ag’y
- Personal mngrs primarily advise, counsel, direct & coordinate development of artist’s career
- Waisbren even incidental activity in procuring employ’mt is subject to TAA
- Even though rec’d no comp, the 1993 + 1994 agmts provide for comp
- TAA does not expressly exempt procurement where no comp is made
- Ct says abuses should apply equally where deferred benefits from obtaining recording K
- Act requires license even if commission not rec’d
- Chinn v. Tobin
- C + Wampole sign agmt w/T to record & publish music
- C + W gave exclusive recording services to T
- T would be exclusive personal mngr & advisor
- Only songwriting services for T employing an artist does not = procuring employ’mt for an artist
- Holding: nothing in TAA says employers of artists must be licensed under TAA
- Marathon Entertainment v. Blessing
- Actor on Lifetime Show, Strong Medicine, trying to not pay commission to mngr who got her show
- New Test:
- Apply doctrine of severability
- Look at what mngr did
- Not going to declare K null & void ab initio even though was not licensed
- Sever commissions--$ that came from show goes back to artist, but other mngr-related commissions mngr keeps
- Recognition that voiding Ks ab initio was too inequitable on mngrs’ behalves
- Entertainment Rights
- Personal Rights: Publicity
- Right of publicity- right of each individual to control & profit from the commercial value of his or her own ID (property)
- Rationale: protection of a celebrity’s proprietary interest in the development of a marketable image
- Serve societal interests:
- Guard against unjust enrichment (K)
- Financ’l incentive to those who cultivate a unique persona (copyright)
- “Name & Likeness”
- No CL right of publicity in NY
- Issues:
- Is the right of publicity descendible?
- Conditional?
- Commercially exploited during person’s lifetime?
- If yes, how long does right last?
- Exception for parodies and satires
- Zacchini v. Scripps-Howard Broadcasting, Co. (SCOTUS 1977)
- TV reporter tapes Z’s act—being shot from a cannon—and shows it on TV
- Act is only 15 seconds long
- Rule: Right to publicity value of his performance
- May not use for own benefit the name or likeness of another
- Liable for appropriation over artist’s objection & in absence of license or privilege
- Ohio Supreme Ct said freedom of press requires some breathing room
- Holding: Z not looking for injunction, just wants to be paid—neither the public nor respondent will be deprived of the benefit of petitioner’s performance as long as his commercial stake in his act is appropriately recognized
- SCOTUS looking to protect entertainer’s incentive to encourage protection of this type of work
- Emphasis on the fact that news station showed Z’s entire act
- Powell’s Dissent: report part of an ordinary news program, a total of 15 seconds, which is a routine portion
- Elvis
- When died, most states did not recognize descendibility for right of publicity
- MLK Center for Social Change v. American Heritage Products (11th Cir. 1983)
- Center sued Δ for selling plastic busts of MLK as an “exclusive memorial”
- Set aside 3% of purchase as contribution to Center, but trust fund for Center was never executed
- District Ct found Δs had infringed MLK’s copyrights and ordered to discontinue use of Center’s name in promoting busts
- Issue: Did District Ct err in finding that not necessary to determine devisability of right of publicity b/c MLK never commercially exploited this right during his lifetime?
- Holding: appropriation of another’s name and likeness for financial gain is a tort in GA & measure of damages is the value of the appropriation to the user, the right is inheritable and devisable, & exploitation beyond the activity which made him famous is not now required
- As long as could have exploited, does not matter that he chose not to
- Invasion of privacy loose collection of 4 torts:
- Intrusion upon ’s seclusion or solitude
- Public disclosure of embarrassing private facts
- Publicity placing in false light in public’s eye
- Appropriation for Δ’s advantage of ’s name or likeness
- Justice Weltner saw no reason to create a new right – right to publicity, he felt case could have been adjudicated based on unjust enrichment
- This case is pretty one of a kind—most cts say commercial exploitation is necessary for devisability
- “Soundalike” Cases
- Midler v. Ford Motor Company (9th Cir. 1990)
- Bette Midler declined to participate in Ford commercial
- Ford chooses to use a former backup single to imitate Midler’s voice & style making it appear like Midler is actually in commercial
- Media’s use of a person’s ID:
- Informative or cultural—immune from suit
- Exploitative—not immune
- Holding: a voice is distinctive & personal & only when a distinctive professional voice is deliberately imitated to sell a product have the sellers misappropriated what is not theirs & committed a tort
- A voice is not copyrightable, so not a copyright infringement
- Also defrauded the public
- Waits v. Frito Lay
- Waits sued Frito Lay for using a sound alike recording to advertise Doritos
- Used an impersonator
- Holding: invaded a personal property right
- Damages for peace, happiness & feelings
- Can’t take an artist’s persona & use it to your benefit w/o permission
- No clear line—ct has to decide whether person is famous enough or voice is distinctive enough
- BUT you can always get an injunction to stop someone from using it, the issue is that the more famous you are, the greater damages you get
- Trademark
- Can be:
- Name
- Logo
- Symbol
- Purpose:
- Origin of the goods or services being sold
- Makes sure the public knows who the originator is
- Can ID as:
- The Company that creates the work
- Dreamworks, Columbia Records
- Service Mark
- Band’s name
- Trade name
- Business & good will associated w/ company
- TM can’t be descriptive, but may be suggestive
- Can’t TM “car,” but may be able to TM “gas mobile”
- Lanham Act
- Prohibits false representation likely to cause public confusion about the origin or sponsorship of the goods/services/trade name
- 3 factors for COA:
- Must involve goods or service
- Must deal w/ interstate commerce
- False designation or description
- Remedies:
- Legal fees
- Punitive damages
- Injunctive relief
- Example of John Doe Warrant for merchants who sell stuff outside of a concert:
- Lawyer goes to court the day before the show asking for John Doe Warrant saying they have probable cause to believe bootleg merchandise will be sold outside of show by ppl whose ID cannot be specifically named
- People- can’t get TM in your name until ppl know who you are & name creates designation that mention of brings to mind a certain kind of service
- Can TM:
- Title of movies, albums, books
- Title of song?—highly debatable
- First user of name wins on TM
- Geographic strength
- Limitations: Can’t TM geographic area
- Supermarts- McDonald’s, Burger King, Etc.
- TM very important for bands to determine who owns rights to the band name w/in the band
- Sound Recordings
- Four multinat’l companies:
- Warner Music Group
- EMI
- Sony/BMG Music
- Universal Music Group
- Music-two types of copyrights:
- Sound recording
- Capturing of the performance w/ some kind of technology that can capture the performance to be played back at another time
- Author is the performer
- Anyone can do a cover song if secure a § 115 license
- Underlying musical compositions
- Words and music
- Sometimes the music itself
- Author is the songwriter, but usually transfer rights to the music publishing company that hired them
- Music publishing deal is usually split 50-50
- About 70% of artists are also the songwriter
- Terrestrial sound recording bills creates way for artists to get paid for performance on radio
- Terrestrial radio does not have to pay recording artists
- Compulsory license: gov’t sets price for use of song so that song being performed/published/recorded can be used by anyone
- Statutory:
- Telecommunications Act of 1933
- Made pay only practice illegal
- Digital Performance in Sound Recordings Act (1995) – provided an exclusive right wrt interactive & subscription service which gave listener ability to select or to predict what would be broadcast
- Digital Millennium Composition Act (1995): Compulsory license for other digital broadcast services of a non-interactive, non-predictable nature
- Contracts in the Recording Industry
- Only officers of record co. have authority to sign artists to what is usually an exclusive recording agmt
- Artist revenues:
- Recording
- Publishing
- Touring
- Merchandise sales
- Definitions:
- Masters- recordings from which replications can be made
- Material Terms in a Recording Agmt
- ASK:
- What leverage does the artist have?
- What does the artist ask for during the negotiation?
- Record Company Commitment
- Demo – only in “no-guaranteed option” agreement
- Single - used to promo – now required because of digital downloads
- Album – usually one album is guaranteed, up to six or seven optioned - label must exercise options to get additional albums
- Term, Record Company Options and Recording Obligations
- Number of Option Periods
- Major Label:6-8 album cycles
- Independent Label:3-5 album cycles
- Minimum Recording Obligation – One LP (vinyl record) for each album cycle
- For a group—leaving member clauses
- Pay or play clauses
- Territory
- North America, World, Universe
- Split Territory deals
- Advances
- Advance plus Recording Cost Budget
- Promotions are considered costs, i.e., deficit tour funding
- All-in Recording Fund - must pay advance and recording budget from this fund
- Recoupment – No royalties paid to artist until all costs and advances are recouped by record label
- Costs could be recording/video costs, tour support, promotion, indie radio promotion
- One of the biggest problems with record deals
- When artist signs deal, gets small advance & record label pays for everything recoupable $ comes from artist’s royalties not the gross record sale
- Biggest charge against the artist was Payola
- $500K advance w/ 15% royalty, usually takes 250K copies sold to break even
- First Album vs.