Before the creation of performance rights, some artists still used the courts to assert control over theatrical works. However, litigants framed the value of performance primarily in terms of the medium’s social and political value, rather than its economic or artistic worht. In litigation involving Charles Macklin, and a later case pitting Robert Elliston against Lord Byron, parties sought to protect performances that upheld their social status or protected the political power of the royal patent theatres. The chapter closes with the legislation that created performance rights in the UK, in which Parliament evinced a strong concern for national pride and literature and relatively little interest in the value of performance itself.