Zusammenfassung

The article deals with the different approaches adopted by American, and other European legal systems as to the possible infringement of the personal features of the recognized individuals. It starts with explaining an idea of the “right of publicity” - a doctrine rooted in the American jurisprudence which influenced the European civil law systems which started to recognize an economic value of the certain personality rights, especially right to privacy. The approach adopted by the American doctrine moves toward a proprietary right, while the European, except for the UK, still remains within the theory of rights of personality. Despite the theoretical differences, the model is still basically the same in all legal systems and simply indicates the right to control the commercial exploitation of persona, professional sportsman included.