Greenfield v. Philles Records, Inc.
New York Court of Appeals
780 N.E.2d 166 (2002)
The Ronettes (plaintiffs) signed a 1963 contract giving Philles Records (PRI), owned by Phil Spector (defendants), full ownership of all master recordings, subject to a royalty schedule, with language authorizing PRI to make reproductions including "phonograph records, tape recordings or other reproductions"; in the 1980s, PRI began licensing the master recordings for movies, television, and compilation albums without paying the Ronettes any royalties. The Ronettes sued, arguing the 1963 contract didn't authorize this kind of 1980s licensing, and the trial court and Appellate Division agreed, finding the contract's silence on these uses meant PRI lacked the right to license them; PRI and Spector appealed.
Whether a recording contract's silence on licensing master recordings for uses like movies, television, and compilation albums renders the contract ambiguous, permitting resort to extrinsic evidence of the parties' original intent.