Bartsch v. Metro-Goldwyn-Mayer, Inc.

How later courts describe this case

• "libel per se is any publication which exposes a person to distrust, hatred, contempt, ridicule, obloquy".
• broad conveyance of motion picture rights encompassed all uses that might reasonably fall within the medium described by the license
• grant of “exclusive moving picture rights” included right to “talkies” even though such technical improve ment may have been unknown and not within contemplation of parties at time of grant
• “[i]f the words [of the license] are broad enough to cover the new use, ... the burden of framing and negotiating an exception should fall on the grantor” of the licensed rights