New York's right of publicity statute, Civil Rights Law §§50, 51, precludes use of a person's identity in advertisement or trade without his or her written consent. A recent Second Circuit decision, Electra v. 59 Murray Enterprises (2021), held that written releases provided by models to photographers, which provided full permission to use all rights in the photographs, did not suffice to satisfy the statute's requirement of "written consent." The businesses who used their photographs were thus liable under the statute.