comparative study of the nature of celebrities’ image rights in commercial advertisements

nowadays, images of celebrities are used to advertise goods and services, and this phenomenon is growing. on the one hand, in recent years, celebrities become aware of the value of image and image rights in advertisement world. on the other hand, many agencies and owners of goods and services become aware of the important effect of popularity of celebrities as a tool to boost sales of goods. therefore, in today’s world, celebrities’ image rights become a valuable asset. there is not a uniform procedure among legal systems in respect of nature of celebrities' image rights. the legal system of the united states has recognized the economic value of image by accepting it as a right of publicity and has been considered it as an economic right. in european countries, france still remains in the framework of right of personality while in legal system of england, image rights is described within right of privacy. by considering the differences in this field, this paper seeks to explain the adopted approaches in legal systems, and analyze the nature of image rights in iran.