Read, Eagles, Read: Royalties for AJ Brown’s Public Quest for “Inner Excellence”?
By Maddie Braksick; Photo Credit: Andy Lewis/Icon Sportswire
Many motivational and positive quotations revolve around the idea that “you never know who’s watching.” While the phrase is meant to promote kindness and good behavior, it also has developed a second meaning in the digital age where individuals, especially celebrities, must be aware of, and careful with, their actions, because something as simple as a phone camera can expose them to the world.
Philadelphia Eagles’ player AJ Brown has been used to the idea of individuals watching him. The 27-year-old wide receiver was a top high school recruit, brief San Diego Padres player, star collegiate player at Ole Miss, then since starting his professional career with the Tennessee Titans has emerged as a powerhouse player for the Eagles.[1] While his actions on the field have certainly been notable, Brown also has emerged as a public figure and mental health advocate off of the field, speaking openly about his own battle with depression, and launched his own A.J. Brown Foundation to help foster resilience in youth.[2] Most recently, however, Brown’s clear passion for self-improvement was demonstrated right on the sideline, when Fox Sports cameras caught Brown reading a self-help book in the middle of the Eagles’ January 12th matchup against the Green Bay Packers.[3] Fans immediately tracked down the book, entitled Inner Excellence: Train Your Mind For Extraordinary Performance and the Best Possible Life by Jim Murphy, and the book quickly soared from 523,497th to the #1 bestseller on Amazon[4].
While fans conjectured across social media platforms wondering if Brown was throwing shade at his quarterback, or attempting to be funny, the receiver quickly debunked the rumors, sharing that he brought the book to every game.[5] The only change this time was that it was caught on camera.
Even nearly two weeks since the viral footage, Inner Excellence remains at #2 on the Amazon bestseller list.[6] The comments on the reviews have shifted from testimonials about the impact of the book on individuals, to reviews entitled “Go Birds” that not only rave about the content of the book, but also explicitly identify that Brown was the motivating factor for their purchase of the book.[7] The author, Jim Murphy, has soared in fame and even was a guest of honor at the Eagles’ Divisional Round on January 19th.[8] Murphy’s life had undoubtedly been changed.
The increase in book sales, influx of interview opportunities, and sudden fame and fortune of Murphy begs the question: in an age where Name, Image, and Likeness (NIL) and the Right of Publicity for college athletes are at the forefront of legal discourse, is Brown as a professional athlete entitled to any royalties or compensation for his endorsement?[9]
The short answer is, no. In order for an athlete like Brown to receive revenue for book sales after the footage of him with the books was publicized, there would need to be specific agreements and rights involved. While an individuals’ Right of Publicity protects their control of the commercial use of their name, image, and likeness, a professional football player like Brown, especially during the course of a game, is already subject to plenty of commercial use of his image, which precludes any claim that his privacy and image were invaded for the sole purposes of promoting the book.[10] Furthermore, athletes enter into licensing agreements with their league, team, any applicable players’ unions and third parties that permit those parties to commercially exploit their images for purposes like broadcasting.[11] In the NFL specifically, players authorize the NFL to use their name and picture for promotional materials, including broadcasts, and more.[12] Furthermore, Brown chose to endorse the book further after the footage of him reading on the sideline was publicized, constituting entirely consensual conduct with no “catch.” If Brown had explicitly formed an endorsement agreement with Murphy and his publishers to promote the book akin to, say, Troy Polamalu with Head and Shoulders, then he may be entitled. Otherwise, no dice.
To compensate celebrities for incidences like this would open an entirely unnecessary can of worms. Should Jennifer Anniston be compensated by Prada for photos of her grocery shopping with their sunglasses on? Probably not.
Ultimately, Murphy isn’t letting the influx of fame get to his head; he insisted to the media that the rise of Inner Excellence wasn’t a vehicle for his own success, but rather the spread of a message that “your value does not come from your performance. There’s so much more to life than just catching footballs.”[13] Furthermore, Brown may not care at all. The athlete, complete with a $100 million contract from the Eagles, may just want to be left alone to read.
Maddie Braksick is a 2L at Vanderbilt Law School from Pittsburgh, Pennsylvania. She graduated from Duke University in 2020 with double majors in Public Policy and Global Health, and a minor in Policy Journalism and Media Studies.
[1] A.J. Brown, Philadelphia Eagles https://www.philadelphiaeagles.com/team/players-roster/aj-brown/ (last visited Jan. 21, 2025).
[2] Id.
[3] Sean Neumann, Philadelphia Eagles’ AJ Brown Goes Viral for Reading Inspirational Book on Sideline During Playoff Game, People Mag. (Jan. 13, 2025), https://people.com/philadelphia-eagles-aj-brown-goes-viral-reading-sideline-during-playoff-game-877334.
[4] Declan Walsh, Jim Murphy, author of ‘Inner Excellence,’ talks about his book going viral thanks to A.J. Brown, 247 Sports, (Jan. 19, 2025), https://247sports.com/article/jim-murphy-author-of-inner-excellence-talks-about-his-book-going-viral-thanks-to-aj-brown–244435017/.
[5] CBS Sports, A.J. Brown on why he was reading a book on the sideline against the Packers, YouTube (Jan. 12, 2025), https://www.youtube.com/watch?v=QqAnpEWOse8.
[6] Amazon Best Sellers, Amazon, https://www.amazon.com/Best-Sellers-Books/zgbs/books (last visited January 21, 2025).
[7] CBS Philadelphia (@cbsphiladelphia), Instagram (Jan. 13, 2025), https://www.instagram.com/cbsphiladelphia/?utm_source=ig_embed&ig_rid=33061ee8-8a1c-4808-a173-2da33620034.
[8] Jeff Kerr, Eagles vs. Rams: ‘Inner Excellence’ author Jim Murphy in attendance at game, A.J. brown holds copy in stadium, CBS Sports, (Jan 19, 2025), https://www.cbssports.com/nfl/news/eagles-vs-rams-inner-excellence-author-jim-murphy-in-attendance-at-game-a-j-brown-holds-copy-in-stadium/.
[9] § 12:10. Name, image, and likeness, Fundamentals of Sports Law § 12:10.
[10] Anthony J. Dreyer et al., In brief: sponsorship and image rights of professional athletes in USA, Lexology, (Aug. 28, 2020), https://www.lexology.com/library/detail.aspx?g=7cb19572-e467-4c8e-a29c-f3a20c169645#:~:text=Athletes%20enter%20into%20licensing%20agreements,a%20large%20number%20of%20players.
[11] Id.
[12] Id.
[13] Walsh, supra note 4.