Marilyn Monroe LLC's claim to exclusive ownership of Monroe's publicity rights became subject to a "landmark [legal] case" in 2006, when the heirs of three freelance photographers who had photographed her—Sam Shaw, Milton Greene, and Tom Kelley—successfully challenged the company in courts in California and New York.[1][2] In May 2007, the courts determined that Monroe could not have passed her publicity rights to her estate, as the first law granting such right, the California Celebrities Rights Act, was not passed until 1985.[45][lower-alpha 3]