Princess Diana did not effectively protect the exploitation of her likeness in the U.S. during her lifetime, and her successor in interest, the Princess Diana Fund, failed in the lower court level against the Franklin Mint, which had been making Diana merchandise pretty much from the day of her wedding to Charles. This Ninth Circuit decision affirms the lower court, and includes an interesting discussion of the post-mortem right of publicity in California, trademark fair use, and the awarding of attorneys fees.