My Image is My Property - Personal Image Protection on the Internet

Abstract

The protection of one’s own image on the Internet is a controversial legal issue that encompasses both economic and dignity aspects of one’s personality.

This paper aimed to bring an overview of de jure and de facto situation of one’s image protection on the Internet.

Four jurisdictions will be discussed in this paper - two common law jurisdictions: United States and United Kingdom; and two civil law jurisdictions: Germany and France. Despite the Internet’s non-boundary nature, and notwithstanding the private international law rules, the infringements of one’s right to his/her own image fall within the scope of the applicable law of the jurisdiction concerned. Therefore each jurisdiction was analysed separately in accordance with the existing legal rules and case law.

Keywords: publicity, personality, rights, image, rights, internet, humiliation, dignity, persona, indicia

JEL Classification: K13, K33, K39