"In the aftermath of Elvis Presley Estate litigation flurry, the Tennessee General Assembly enacted the Personal Rights Protection Act of 1984, providing clear statutory language ensuring personality rights are not extinguished at death and their descendibility to others. Additionally, the Tennessee Court of Appeals confirmed the descendibility of personality rights under common law in another case brought by the state against the “Elvis Presley International Memorial Foundation” for their unlicensed use of Elvis's name. The foundation argued there was “no descendible right of publicity in Tennessee and that Elvis Presley's name and image entered into the public domain when he died. The court made a clear distinction between the right to privacy and right to publicity, highlighting the economic value of a celebrity’s image, and in reviewing the Sixth Circuit's previous opinion on the matter, found their prior decision was made “without considering Tennessee law. Instead, the court recognized Tennessee has an “expansive view of property” and concluded a celebrity's right of publicity is a “species of intangible personal property” protected in Tennessee. Specifically, the court found descendability of personality rights promotes "an expectation that the investment in valuable capital assets will benefit one's heirs after death, the protection of contract rights, the discouragement of consumer deception, and the policy against unfair competition.Thus, the court held "Elvis Presley's right of publicity survived his death and remains enforceable by his estate and those holding licenses from the estate."