May 19, 2001
VIA FAX to 412/761-0212
Ray Howard
President,
ALSA, Inc.
607 California Ave.
Pittsburgh, PA 15202
Re: Your
Request for a Legal Opinion
Dear Mr. Howard;
I received your undated letter re: "Conflict of Interest" on May 17,
requesting legal guidance by May 23.
I have reviewed the limited material (highlighted portions from the "AOBA
Show Handbook" that accompanied your letter.
Ms. Schofield contacted me on May 18 and requested my fax number so she could
forward items to me as well. I have reviewed the 10 pages of materials she
sent consisting of a "Show Administrator Agreement" an opinion letter from
her lawyers and other correspondence.
From the review of these materials, I feel that I am
seeing the mere tip of the iceberg. The materials raise many
questions, however, I do not feel that I possess
sufficient knowledge of the facts to offer helpful guidance at this point in
time.
To competently advise ALSA, I feel that I must be brought into the loop,
permitted a significant opportunity to discussion with persons with
first-hand knowledge of the facts, and participate with the ALSA board in a
discussion of the organization's legal objectives in light of the facts, once
they are established.
From review of the limited materials; however, I do appreciate your
concerns. I do not believe the opinion letter of Ms. Schofield's lawyer,
which suggest Ms. Schofield is legally free to accept employment as the Show
Administrator for AOBA, was based upon rigorous review of the facts nor the
broad range of fiduciary duties that directors owe to the corporations they
have been selected to run. I am concerned that those lawyers failed to
appreciate the significant nor application to these facts of a director's
fiduciary duty neither to compete directly against, nor usurp the business
opportunities of the corporation.
To explain this doctrine, I provide two quotations from a legal encyclopedia.
The first quote explains the general rule; the second discusses how the rule
has been applied to specific cases: "A corporate officer or director is
under a fiduciary obligation not to divert a corporate business opportunity
for his own personal gain. The rule is that if there is presented to a
corporate officer or director a business opportunity which the corporation is
financially able to undertake, which is from its nature in the line of the
corporations business and is of practical advantage to it, and which is one
in which the corporation has an interest or a reasonable expectancy, and if,
by embracing the opportunity, the self interest of the officer or director
will be brought into conflict with that of this corporation, the law will
not permit him to seize the opportunity for himself. If he does, the
corporation may claim the benefit of the transaction. This doctrine of
corporate opportunity is a species of the duty of a fiduciary to act with
undivided loyalty; it is one of the manifestations of the general rule that
demands of an officer or director the utmost good faith in his relation to
the corporation which he represents."
18B Am. Jur.2d
"Corporations" S1770 "Appropriate of Corporate Opportunities,
Generally" "Since the question whether a director or
officer has appropriated for himself something that in fairness should belong
to his corporation is a factual one to be decided by reasonable inference
from objective facts, the result in any particular case has hinged on the
surrounding circumstances and particular actions that allegedly constituted a
breach of the corporate opportunity doctrine. Thus most cases involving the
taking of a corporation's customers by an officer or director have resulted
in the officer or director involved being held liable for a breach of the
doctrine. Similar results have been reached in cases involving interference
by officers or directors with their corporations' interest or expectancy in
the lease of business premises, sale of stock in competition with their
corporations, and the purchase by officers or directors of outstanding
financial obligations of their corporations. Cases involving opportunities
to take advantage of interests in oil, gas or mineral properties appear to
turn largely on whether the opportunity presented is speculative and in the
line of the corporation's business. When the opportunity is in the line of
the corporation's business, a violation of the doctrine is likely to be held
supportable, while opportunities that are highly speculative or of a
different type than that ordinarily pursued by the corporation are likely to
result in a contrary determination. Similarly, actions involving the
providing of goods and services, the purchase of property or manufacturing
machinery, or the purchase of shares in other corporations, appear to have
results that depend on whether the corporations involved had taken an active
interest in the opportunities presented."
I also share your concerns that the wholesale plagiarism of ALSA materials
(assuming they were published with copyright notices; and further complicated
by uncertainty about the origin and authorship of the materials in question),
and their republication by AOBA under claim of copyright, violates ALSA'S
rights protected by the federal copyright laws.
I offer a few statements of the rules which may have been violated by AOBA'S
usurpation of ALSA'S handbook.
"The Copyright Act of 1976 lists five fundamental exclusive rights
which the statute gives to copyright owners; the rights of reproduction,
adaption, distribution, performance, and display. These exclusive rights,
which comprise the so-called 'bundle of rights', are cumulative and may
overlap in some cases. The copyright owner has the sole right to exercise
any of the exclusive rights of copyright and conversely, to exclude others
from exercising any such rights, but these broad rights are qualified by
various limitations enumerated in the statute. The protection accorded a
copyright owner by the statute has never accorded the copyright owner
complete control over all possible uses of his work; rather, the Copyright
Act grants the copyright holder 'exclusive' rights to use and to authorize
the use of his works in only five qualified ways. Hence, an unlicensed use
of a copyright is not an infringement unless it conflicts with one of the
specific exclusive rights conferred by the copyright statute. Each of the
five enumerated rights may be subdivided indefinitely and each subdivision
may be owned and enforced separately."
18 Am.Jur.2d. "Copyright and Literary Property" S70, "Statutory Rights
Generally"
Unfortunately, I will be out of my office from May 21 to May 28, and cannot
participate in your board meeting scheduled for May 23.
I would be willing to undertake an assignment to pursue the legal questions
raised by your correspondence and this reply, if retained by the ALSA board.
In June and July, I would be able to devote a significant block of time to
the assignment.
Very truly yours,
Terry Price
Thornton W. Price III