"Thus, the Players, who were neither requested nor agreed to limit the display or depiction of the images tattooed onto their bodies, had implied licenses to use the Tattoos as elements of their likenesses."

I've mentioned before that there have been a series of lawsuits against sports video game makers by tattoo artists (for example, where the LeBron James character in a video game includes LeBron James's actual tattoos). Well, one video game maker has just won a significant victory in the Southern District in one of the cases, including (but not only) on implied license grounds, which should make Christopher Sprigman and Annmarie Bridy happy. Story here. Opinion here.