"Furthermore, the Image's blatant, vile, and unauthorized misappropriation of Ms. Raymond's name and likeness, and your conduct in using the Image on your Site, have caused immeasurable harm to Ms. Raymond's reputation and career, and constitute an egregious infringement of Ms. Raymond's personal rights and privacy rights...

Any person who knowingly uses another's name, .., photograph, or likeness, in any manner, on or in products, merchandise, or goods, or for purposes of advertising or selling, or soliciting purchases of, products, merchandise, goods or services, without such person's prior consent&shall be liable for any damages sustained by the person or persons injured as a result thereof."