Panayiotou v Sony Music Entertainment (UK) Ltd

Panayiotou and others v Sony Music Entertainment (UK) Ltd. ([1994] ChD 142) was a contract and entertainment law case before the High Court of Justice's Chancery Division. The plaintiff, entertainer George Michael, argued that his recording contract constituted an unreasonable restraint of trade. Michael alleged that the defendant had failed to promote his album Listen Without Prejudice Vol. 1 with due vigour as punishment when the artist decided to downplay his status as a sex symbol. Michael described his situation as "professional slavery" because his contract required that he produce music and cede the copyright to Sony for many years, leaving him no control over how the music would be marketed nor placing a reciprocal requirement that the label invest in promotion. Had the case succeeded, it might have curtailed the practice of signing artists to multi-album contracts. The court wholly rejected the claims.

Georgios Panayiotou, known professionally as George Michael, signed with Innervision Records in 1982 at the age of eighteen as part of the then relatively unknown pop duo Wham!. Innervision were distributed by CBS Records. In 1984 this contract was nullified as part of a legal compromise wherein Wham! were obligated to produce up to eight new albums for CBS Records; the label and the contract were acquired by Sony Music Entertainment in 1987. Following Wham!'s success and subsequent break up, Michael renegotiated a new eight-album deal with Sony as a solo artist in 1988. This deal was further renegotiated in 1990 to reflect Michael's superstar status, achieving terms comparable to similarly high-grossing artists. Michael's first solo album, Faith, was released in 1987 and had sold 14 million copies by the time suit was filed; his second solo album, Listen Without Prejudice Vol. 1 was released in 1990 and had sold 5 million copies.Listen Without Prejudice represented a new direction for Michael, downplaying the sex symbol status he had cultivated with Wham! in favour of a more reserved identity purely as a serious musician; he decided not to place his highly recognisable image on the album cover and declined to appear in promotional videos. Michael alleged that Sony under-promoted his new album in response to these decisions. He further charged that the contract restricting him from seeking a new label prevented him from managing his professional image as he saw fit. Michael described this imbalance of power and his long-term lack of control over his career as "professional slavery".

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