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Are you saying they had to buy Davis' rights to identify him in a photo and then didn't print a card of his as well?
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No, they already would have had the rights to/ permission of Harry Davis--he was in t206, as were Birdie Cree and Billy Sullivan, two others identified in the back caption but missing from the end panels. Joe Jackson, by contrast, does not appear to have ever lent his permission to ATC.
I do not follow your Conlon analogy. Conlon also took virtually all of the portrait shots used in the E254 Colgan set. Are you suggesting that Colgan needed only to buy Conlon's permission to crop and use these photos, and not the players? I very much doubt that.