David commented on a recent decision by the Second District Court of Appeal in the Los Angeles Daily Journal in a case involving a television station's use of material created by a former employee. He notes that the court's unanimous decision affirms the common understanding of right of publicity, and that the station was well within their bounds to use the former employee's likeness for "incidental advertising use." ("TV Station Knocks Out Right of Publicity Claim Win on Appeal," September 7, 2016)