Harms JA observed the following in the judgment of the Supreme Court of Appeal in South African Football Association v Stanton Woodrush (Pty) Ltd t/a Stan Smidt & Sons & Another 2003 (3) SA 313 (SCA) at 321E-G: 'Character merchandising has become somewhat of a catchphrase, but as so often is the case, catchphrases tend to obscure rather than enlighten. The concept arose in the licensing of famous comic book characters, such as Mickey Mouse. But licensing the use of such characters was nothing more than a copyright licence. Next to develop was personality merchandising, the licensing of the names of famous persons such as sportsmen, which in our law amounts to the commercialisation of personality rights. Last, there is the merchandising of well-known trademarks or of other reputations protectable by a passing-off action. This means that 'character' merchandising rights are not new rights. One is simply dealing with the application of existing principles to new commercial realities.' With reference to this view regarding the 'commercialisation of personality rights', critically evaluate all the currently available legal bases for protection in South African law in cases of celebrity (or personality) merchandising, and the related issue of professional athletes' image rights with reference to case law. Word count must be between 1200 - 1500 words.