Greenfield v. Philles Records Inc

In Greenfield v. Philles Records Inc., 98 N.Y.2d 562 [2002], the Court of Appeals, interpreting a recording artist's contract transfer of ownership rights to a record company, held that in the absence of "an explicit contractual reservation of rights by the artists," the "artists' transfer of full ownership rights to the master recordings of musical performances carried with it the unconditional right of the producer to redistribute those performances in any technological format." (98 N.Y.2d at 566.) That case involved the right of Philles Records to license master recordings for synchronization and redistribution of domestic licenses in 1987 based on a 1963 contract. The Court found that, despite the technological innovations that are revolutionizing the recording industry, long-settled common-law contract law governed. The broad contractual provisions of the agreements conveying to the defendants the "right to make phonograph records, tape recordings or other reproductions of the performances embodied in such recordings by any method now or hereafter known" (id. at 568-569) was a clear and unambiguous provision that authorized defendants to license performances for use in all visual media, i.e., television or movies. The Court stated that "a written agreement that is complete, clear and unambiguous on its face must be enforced according to the plain meaning of its terms." (Id. at 569.)