Source: Wikimedia Commons,

By Kiarra Strocko

Ever since the seventh season of the hit television show Game of Thrones was released, the topic of the Lannisters, Daenerys Targaryen, and the White Walkers has been on every viewers’ minds. .[1] The complaint involving  Coster-Waldau and Impression Entertainment, Inc. was filed on July 28, 2017 in the Superior Court of the State of California in Los Angeles.[2] Littman is currently seeking unpaid commission for Coster-Waldau’s role in the hit Home Box Office (“HBO”) show.[3] However, Coster-Waldau states that he merely had an “Oral Management Agreement” with Littman.[4] The documents Littman provided are allegedly “sham documents” because Coster-Waldau claims he only signed them to support Impression Entertainment’s sponsorship of his visa.[5] In addition, although Coster-Waldau sent an email to Littman and proceeded to end the business relationship, he admitted that he would continue to pay her throughout the seventh season of Game of Thrones and mentioned how Littman was like a friend to him.[6] Ultimately, the court needs to determine if any of the written documents exchanged between Coster-Waldau and Littman should be recognized as legally binding agreements, which would result in Coster-Waldau paying Littman for her management services.[7] The issue of contract fraud in the entertainment industry is relevant and important because agencies rely on these contracts to gain commission or employment and actors rely on the contracts for representation in a highly competitive industry.[8]

Without contract reliability, businesses cannot be held accountable for their agreements and may refuse to enter into contracts which could affect the economy.[9] An example of this issue is a recent contract dispute that was filed on October 31, 2016 by producer Jason Lust regarding his contractual relationship with his agent Zareh Nalbandian.[10] Lust and Nalbandian discussed Lust playing roles in animation production for projects such as Peter Rabbit, Betty Boop, and Astro Boy.[11] The parties allegedly discussed initiating a partnership that took advantage of Lust’s connections within the entertainment industry.[12] They established a short form agreement which included language that suggested Lust’s duties with Animal Logic Entertainment as an independent contractor not a partnership.[13] In the end, the parties never executed a long form agreement and Nalbandian allegedly did not intend to continue with their partnership once Animal Logic Entertainment became successful.[14] Even though this case has not been resolved, it is similar to Coster-Waldau’s case because Coster-Waldau also did not intend for the written agreements and discussions with Littman to be a binding set of terms.[15]

Another contract fraud case from July 1951 that is similar to Coster-Waldau’s case is Mandel v. Liebman.16 Entertainment manager Louis Mandel sued Max Liebman, a writer and director, for unpaid compensation in relation to a five-year contract with over a ten percent commission owed to Mandel for management services.17 The Court of Appeals of New York found in favor of Mandel because the original contract was legal and recognized as enforceable by the courts.18 The appellate court’s judgment in favor of Liebman was reversed by the court of appeals because the contract stated that Liebman agreed any earnings during the contract or future earnings for the company would be due to Mandel for the agreed upon percentage.19 Mandel was required to perform some services for Liebman under the agreed-upon contract and Liebman was required to pay for the services regardless of whether it resulted in a good or bad bargain for Liebman.20 This case is similar to Coster-Waldau’s case because they both deal with potentially void and unconscionable entertainment industry contracts relating to unpaid compensation.22

In his email terminating Littman in 2015, Coster-Waldau stated that he would give her the financial rewards from the seventh season of Game of Thrones.23 If the court rules that Coster-Waldau does not need to uphold his end of the contractual agreement on the ground that the contract between him and Littman is legally unenforceable, then it could set a precedent that written agreements and discussions do not necessarily need to be enforced even if they were signed and significant consideration was given.24

[1] Ashley Cullins, Game of Thrones’ Star Nikolaj Coster-Waldau Sues Ex-Manager for Fraud, The Hollywood Reporter (July 28, 2017),

[2] Coster-Waldau v. Impressions Enter., Inc., No. BC670246, 2017 WL 3215179, at *1, 2 (Cal. Super. July 28, 2017).

[3] Id.

[4] City News Service, Game of Thrones’ Star Sues Manager Over ‘Sham’ Contract, NBC San Diego (July 29, 2017),

[5] Cullins, supra note 1.

[6] 2017 WL 3215179, at *2.

[7] Id.

[8] David Ng, SAG-AFTRA reaches new contract deal with studios, L.A. Times (July 4, 2017, 9:00 AM),

[9] Deepak Malhotra, When Contracts Destroy Trust, Harv. Bus. Rev. (May 2009),

[10] Ashley Cullins, Producer Sues Animal Logic Over ‘Peter Rabbit,’ ‘Lego Movie’ Sequels, The Hollywood Rep. (Oct. 31, 2016, 7:07 PM),

[11] Id.

[12] Id.

[13] Patricia Millet, Producer Claims Fraud In Connection With Children’s Entertainment Partnership, Forbes (Nov. 9, 2016),

[14] Id.

[15] City News Service, Game of Thrones’ Star Sues Manager Over ‘Sham’ Contract, NBC San Diego (July 29, 2017),

16 Mandel v. Liebman, 100 N.E.2d 149, 151 (N.Y. 1951).


17 Id. at 150.

18 Id. at 155.

19 Id. at 153.

20 Id.

21 See Coster-Waldau v. Impressions Enter., Inc., No. BC670246, 2017 WL 3215179, at *1, 2 (Cal. Super. July 28, 2017); Mandel v. Liebman, 100 N.E.2d 149, 151 (N.Y. 1951).

22 Sara Boboltz, Game of Thrones’ Star Sues Former Manager Over Alleged Deception, Huffington Post (July 29, 2017),

23 Id.

24 Deepak Malhotra, When Contracts Destroy Trust, Harvard Business Review (May 2009),

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