WARNER BROS PICTURES INC V NELSON [1937) 1 KB 209 Early in her career, Bette Davis signed a contract with Warner Bros movie studio.35 That agreement contained positive and negative undertakings. Positively, Davis promised to act in the studio's films. Negatively, she promised not to act for anyone else. By 1937, however, Davis had enjoyed great success in Of Human Bondage with Leslie Howard, The Petrified Forest with Humphrey Bogart, and Dangerous, for which she won an Academy Award. She therefore decided that her contract with Warner Bros did not pay enough for someone of her stature. She wanted to work elsewhere for more money. Warner Bros did not seek specific performance of Davis's positive promise to perform in its movies. And, indeed, the court said that such an order would not have been granted. The studio did, however, obtain an injunction with respect to the actress's negative promise not to appear in anyone else's movies. The court held that if Davis wanted to appear on film during the life of her contract with Warner Bros, she had to work for that studio. The court also held, however, that she was free to earn a living in other ways if she chose