Diversity-Fraud: Accent Delight v. Sotheby’s

February 15, 2024

Sothebys Trial Sketch, ELIZABETH WILLIAMS <lizillustration@gmail.com>

By Suzanna Neal and the Center for Art Law Team

On January 30th, 2024, the trial of Accent Delight International Ltd. (Accent Delight), an offshore company with Dmitry Rybolovlev as the ultimate beneficial owner, v. Sotheby’s, an international auction house, was put to rest after the jury decided in favor of Sotheby’s. Specifically the jury found that the auction house was not responsible for aiding Yves Bouvier, a Swiss art dealer, in defrauding Rybolovlev of millions of dollars.

Starting on January 9th, the parties pleaded their case revolving around the decade-long legal battle between Bouvier and Rybolovlev, and Sotheby’s alleged involvement. However, this time, Bouvier was not a defendant in this case. Instead, Rybolovlev summoned Sotheby’s into court on the theory that the auction house aided Bouvier in defrauding his client out of hundreds of millions of dollars. The three-week trial offered an informative glimpse into opaque art market dealings, duties of agents, and relationships between the leading private sellers and buyers.

I. BACKGROUND AND KEY PLAYERS

A. THE RESPONSIBLE ART MARKET AND AGENCY IN THE ART WORLD

The discrete nature of the art market has led to its vulnerability to money laundering and fraud through private and often anonymous transactions. ^[1]Recently, the United States, the United Kingdom, and the European Union took steps to address this opaqueness and create a more compliant and fair market.^[2] These strides towards a more principled market have been shown through the EU’s 5th Directive and the U.S.’s Anti-Money Laundering Act of 2020, as well as the Customer Due Diligence Requirements for Financial Institutions.^[3] Leading auction houses like Sotheby’s are expected to abide by global laws and agreed-upon sanctions to even the playing field in selling from different destinations.^[4] Additionally, initiatives such as the Responsible Art Market (RAM) have been formed to raise awareness to the risks of the art market, and to provide practical guidance and resources.^[5] The relevant guidelines are Art Transaction Due Diligence and Art Market Intermediaries. These toolkits provide a guide to the assessment of risks faced as individual collectors or buyers, and also for intermediaries such as auction houses.^[6][7] These toolkits can be found here.

Within the art market are various critical participants such as dealers, agents, advisors, and principals. Not all roles are clearly defined and at times each role can be played by different participants. As a general matter, dealers are expected to act in their own interest, free to buy and sell on their own account, often on behalf of artists, collectors or galleries.^[8] Agents, however, act on behalf of the person they are representing—their principal. Agents have various fiduciary duties owed to their principal, often an art collector, which include keeping their principal informed of anything relevant to transactions, acting in good faith for the principal, and avoiding any situation where the agent’s own interests might coincide with his principal’s.^[9] Due to the difference in whose interest they represent, dealers and agents are mutually exclusive roles.^[10] One cannot act in their own interest as a dealer while simultaneously acting in the principal’s interest as their agent.^[11] Similarly, a seller cannot also simultaneously act as an agent, since sellers have their own personal interests in mind rather than their principal’s interests. Agents often earn a small commission from the works that their principals purchase, while a seller or dealer keeps the difference between what they purchased the work for and what they made off it.^[12]

B. BOUVIER’S AND RYBOLOVLEV’S HISTORY

Rybolovlev, a Russian businessman, in common parlance an oligarch, accumulated his wealth in the fertilizer industry.^[13] He resides in Monaco and is the current owner of AS Monaco, Monaco’s soccer team.^[14] Bouvier, a Swiss Businessman and art dealer, is largely known for his involvement in Art Freeports and the “Bouvier Affair,” referring to the ongoing legal battle between him and Rybolovlev.^[15]

In the mid 1990’s, Rybolovlev and his family moved to Switzerland with his family, and shortly after, he began to collect blue-chip art pieces.^[16] Bouvier and Rybolovlev reportedly met in 2002 at the former’s Geneva Freeport.^[17] At the freeport, shortly after Rybolovlev bought Chagall’s Le Grand Cirque, he became aware of the work’s missing certificate of authenticity.^[18] A despondent Rybolovlev was put at ease when Bouvier came into the picture announcing he knew the seller of the Chagall and a few days later forwarded the certificate of authenticity to Rybolovlev.^[19] This swift placation on Bouvier’s part is what began their relationship, leading him to become a key figure in Rybolovlev’s life for the next twenty years.

While the exact extent of Rybolovlev’s art collection is not known, according to the court filings between 2002 to 2014, Rybolovlev acquired over 38 works with Bouvier’s assistance, including the famous and controversial Salvator Mundi.^[20] Salvator Mundi, attributed to Leonardo da Vinci, a sleeper painting attribution of which has been a subject of much research and debate, and the record setting sale through Christie’s in 2017 for $450 million, was sold to Rybolovle by Bouvier with an approximately 53% markup.^[21] According to Plaintiff’s attorneys, Bouvier’s part in these transactions led to Rybolovlev overpaying by more than $1 billion USD.

In the closing arguments, Plaintiff’s counsel referenced Rybolovlev’s testimony, when he stated that the two developed a close friendship as evidenced by their scheduled monthly lunches, introduction of Rybolovlev’s family to Bouvier, and Bouvier’s attendance of Rybolovlev’s birthday party in Hawaii. Rybolovlev admitted that it’s hard for him to trust people, but once he does, he trusts them entirely. According to Plaintiff’s counsel, this trust is what led him to believe that Bouvier was acting in Rybolovlev’s best interests, instead of his own. The two did not have their relationship in writing, although it was presumed to be an agent style relationship.^[22] During the trial, Sazanov stated that they did have a written agreement which mentioned the commission Bouvier would receive for his work as an agent to Rybolovlev.^[23]

Rybolovlev filed legal claims against Bouvier in Singapore, Hong Kong, New York, Geneva, and his primary residence of Monaco.^[24] In December of 2023, Rybolovlev and Bouvier reached a confidential settlement; ending their 9-year legal dispute.^[25]

C. THE PARTIES

Plaintiffs (at the filing)

Accent Delight International Ltd. (Accent Delight) is an offshore company in the British Virgin Islands owned by family trusts of Dmitry Rybolovlev.^[26]

The second party, Xitrans Finance Ltd., another offshore company owned by Rybolovlev’s family trust, was dismissed from this action with prejudice on August 3rd, 2023.^[27]

Defendants (at the filing)

Sotheby’s, an international auction house, specializes in art and luxury goods, and has been established since 1744.^[28]

Both named plaintiffs, acting for Rybolovlev, summoned Sotheby’s into court on the theory that the auction house aided Bouvier in defrauding Rybolovlev out of hundreds of millions of dollars. The parties agreed to not use the term “oligarch” in the proceedings.^[29]

From the 38 works Rybolovlev bought through Bouvier, 12 were arranged with assistance from Sotheby’s to Bouvier, and only four of those were at issue in trial.^[30] These four include Leonardo da Vinci’s Salvador Mundi, Modigliani’s Tete, Klimt’s Wasserschlangen II, and Magritte’s Domaine d’Arnheim.

According to Rybolovlev, the works were sold to him by Bouvier for a markup of $44,945,000; €31,248,000; $58,956,000; and $19,788,000 respectively. For each of these works Rybolovlev submitted he believed that Bouvier was acting as an agent or advisor, that he was negotiating with a third party to get the seller to mark down the price. E-mails sent from Bouvier to Mikhail Sazonov, Rybolovlev’s former financial officer, reveal that Bouvier was creating these “negotiations” from thin air.^[31]

In 2018, Rybolovlev filed a civil suit in the Southern District of New York against Sotheby’s for allegedly aiding and abetting Bouvier to defraud Rybolovlev through alleged appraisals and inflation of the work’s prices.^[32] In November of 2023, Judge Jesse M. Furman ruled on summary judgment dismissing a number of plaintiff’s claims, except for allegations of aiding and abetting fraud in the four works.^[33]

Samuel Valette, Sotheby’s Senior Vice President, was Bouvier’s liaison at Sotheby’s. He acted as the middleman between the various sellers and his buyer—Bouvier, helping to negotiate all four relevant works at trial for Bouvier to eventually sell to Rybolovlev. According to Valette’s testimony, Valette did not know that after Bouvier bought a piece with Vallete’s help as the intermediary, Bouvier then immediately flipped the work by selling them to Rybolovlev at a higher mark-up.

An aide to Valette for the sale of Salvador Mundi was Alexander Bell, chairman of Sotheby’s UK and Ireland, as well as a specialist in Old Master Paintings.

E. COMPLETE LIST OF WITNESSES^[34]

Plaintiff’s witnesses: Mikhail Sazonov Dmitry Rybolovlev Robert Wittman Guy Stair Sainty Yves Bouvier Sotheby’s Corporate Representative Nicholas Acquavella Claudine Godts (Wildenstein Gallery) Sanford Heller Samuel Valette Bill Ruprecht Alexander Bell Bruno Vinciguerra	Sotheby’s witnesses: Samuel Valette Bill Ruprecht Alexander Bell Bruno Vinciguerra Jane Levine Franka Haiderer Harry Smith

II. ARGUMENTS, ELEMENTS, AND DECISION

For Rybolovlev to prevail in this civil suit, he needed to prove three things. First, that Bouvier committed fraud, second, that Sotheby’s aided and abetted Bouvier in committing the fraud, and third, that Accent Delight suffered damages as a result. His counsel provided numerous emails from Bouvier to Sazonov and Rybolovlev detailing fake negotiations and prices on Bouvier’s part. According to Samuel Valette’s testimony, Sotheby’s also agreed that Bouvier made up these negotiations to trick Rybolovlev into thinking he was getting the pieces for a better deal than he could without Bouvier.

Next, Rybolovlev’s counsel heavily relied on the role that Valette played in assisting Bouvier as his strongest argument that Sotheby’s aided and abetted Bouvier in defrauding Rybolovlev. His counsel declared that, in each transaction of the works, when Sazonov or Rybolovlev questioned the value, Bouvier’s answer was “Sotheby’s.” Emails show Valette sending approximate prices to Bouvier, and then some twelve hours later, sending a much higher price again, in a more formal email. Counsel persuaded the jury to connect the dots that between these two emails, Bouvier must have convinced Valette to raise the price so he could skim more off the transaction to Rybolovlev.

For example, in November of 2011, when discussing the price of Domaine d’Arnheim, Valette first emailed Bouvier saying the price would be approximately 25 million dollars. Shortly after, Valette sends another email to Bouvier, but this time using more formal language, writing the estimate to be between $40-60 million dollars. Counsel focused on Valette’s decision to switch between the informal “tu,” to the more formal “vous” in his second email to demonstrate that somehow Valette knew this second email would be forwarded to Rybolovlev as assurance from Bouvier that Rybolovlev was getting a good price.

A similar pattern followed with Tete in July of 2012 when Valette first wrote the value to be between €70-90 million euros, and shortly after wrote the value was between €80-120 million euros.^[35] Counsel argued that by this point, Bouvier was Valette’s “golden goose,” which is why Bell educated Valette in the Old Masters Department so he could create a pitch for Bouvier to sell to Rybolovlev. Counsel repeatedly stressed the importance of connecting the dots in cases of fraud; even showing how George Seurat’s Sunday Afternoon at the Park looks just like tiny dots up close, until one steps back to take the entire piece in. Lastly, at closing arguments, Rybolovlev’s counsel showed how much Rybolovlev lost in each of the four transactions; all together adding up to approximately $157.5 million dollars.

Sotheby’s defense mainly relied on the fact that they had no knowledge of Bouvier’s deception and made no profit from it. During Rybolovlev’s cross examination, Sotheby’s questioned his track record of making calculating decisions for all his business ventures, but not in his collecting of art.^[36] They argued that he should have approached each of these million-dollar transactions with the same wariness he did with all other aspects of his business affairs; and since he failed to do so, his carelessness was his fault and not the responsibility of Sotheby’s.^[37]

DECISION

After both parties made their closing arguments on Monday, the jury was left to deliberate the three issues that could potentially find Sotheby’s liable; 1) whether Bouvier committed fraud; 2) if Sotheby’s aided and abetted Bouvier in committing the fraud, and 3) that Rybolovlev suffered damages as a result. If the jury found all three to be true, then Sotheby’s could have been found liable for aiding and abetting. Announced January 30th, late afternoon, the jury ruled in favor of Sotheby’s, denouncing the auction house’s role in assisting Bouvier in defrauding Rybolovlev. It is unknown whether the jury found one, or all elements to be true; as we only know their final verdict.^[38]

III. THE IMPACT OF THIS CASE

The verdict relieves Sotheby’s of allegations that they aided and abetted Bouvier in defrauding Rybolovlev.^[39] Had Rybolovlev received an award he sought, namely $10 million dollars, the trial could have had a tumultuous effect on the art market, potentially opening the floodgates for other claims against intermediaries. However, even though Sotheby’s was not found to have aided in defrauding Rybolovlev, the entire trial allowed for a glimpse into an opaque world of private art sales and pricing of unique and rare cultural objects. In closing, Rybolovlev’s counsel stated their goals were not only to recover some of the money lost by their client, but also “to shine a light on the lack of transparency that plagues the art market, and to protect future buyers.”

On that aspect, the trial must have been successful due to its widespread publicity. Although Rybolovlev did not prove what he sought after in this civil suit, he might have succeeded in his goal of bringing awareness to the lack of transparency. Still, one can question whether the steep price of litigation, especially considering its lengthy duration, was worth it in the end.^[40] The trial team for Sotheby’s quotes, “We are pleased with the jury’s verdict, which validates our client Sotheby’s deep commitment to integrity in the fine art market. The verdict fully absolves Sotheby’s of any alleged misconduct.”^[41]

Considering this verdict along with the settlement that Bouvier and Rybolovelv reached in December 2023, it seems that this affair is one to remember.^[42] Not a cataclysmic ending, but certainly one that offers some needed, if not “delighted,” accent on the financial dealings in the art world.

 

Appendix: Who’s Who & Other Resources for Accent Delight v. Sothebys

Parties: Accent Delight International Ltd. & Sotheby’s

Plaintiff’s Attorneys: Ananda Venkata Burra, Andrew K. Jondahl, Ariadne Motta Ellsworth, Douglas Edward Lieb, Ogilvie Andrew Fraser Wilson, Sarah Mac Dougall, Scout Katherine Katovich, Vasudha Talla, Zoe Antonia Salzman, and Daniel Joseph Kornstein.

Defendant’s Attorneys: Marcus Aaron Asner, Mitchell Russell Stern, Sahrula Kubie, Sara Lynn Shudofsky, Yiqing Shi, Benjamin C. Wolverton, Carmela T. Romeo, Kathryn Linde Marshall, Kristina Alekseyeva, Laura Daphne Pacifici, Natalie J. Salmanowitz, Neal Kumar Katyal, and William Havemann.

Judge: Judge Jesse M. Furman is a district judge for the United States District Court for the Southern District of New York. President Barack Obama nominated Judge Furman in 2011.^[43] Read his past cases here.

Jury: Jury Selection

The process of Jury Selection and the Jury Questionnaire aims to gather specific information from potential jurors for the trial. The questionnaire is designed to identify potential biases, conflicts of interest, or pre-existing knowledge that could impact jurors’ ability to objectively evaluate the evidence presented in a legal dispute. The specific questionnaire and selection process for the Sotheby’s trial included several questions that related to art world knowledge and participation, including the following:

• Art World Involvement: Inquires about any experience or training in the art world, including buying or selling art, curating art in a museum, obtaining appraisals, or valuations for art.
• Property Transactions: Asks about involvement in buying or selling property on behalf of others, and whether the juror or close associates have collected art, antiques, or other fine collectibles. Particularly, while observing the proceedings and Jury Selection, a potential juror member who collected Ukrainian art was also asked if they would have any concerns in deciding a case that involves a Russian art collector as well.
• Auction Experience: Inquires about any experiences with purchasing or selling items at auctions and whether such experiences might affect impartiality.
• Foreign Language Understanding: Checks if jurors understand Russian or French, given that testimony in these languages could be part of the trial.
• Views on Fine Art Market Participants: Asks about any positive or negative opinions or feelings towards participants in the fine art market.
• International Elements: Checks if jurors are affected by the fact that some individuals and entities involved in the case are from foreign countries.
• Business Connections: Inquires about any past business connections with Accent Delight International Ltd., Dmitry Rybolovlev, or any Sotheby’s entity. A potential juror mentioned that their family purchased and sold artwork through Sotheby’s as well.
• Familiarity with Potential Witnesses: Lists a multitude of potential witnesses and entities involved in the case, asking jurors if they know or have heard of any of them including names like Yuri Bogdanov, Thomas Bompard, Marc Bonnard, Yves Bouvier, Steve Cohen, Monaco Football Club, Acquavella Galleries, Arrow Fine, Wildenstein & Co. Gallery and many others.

Questionnaire for the Jury Selection can be found HERE.

About the Author:

Suzanna Neal is a legal intern at the Center for Art Law. She is a third year law student at New York Law School.

About the Courtroom Illustration:

Elizabeth Williams, SOTHEBYS TRIAL SKETCH opening statement w plaintiff (Jan. 9, 2024). https://www.elizabethwilliamstudio.com/

Sources:

1. Graham Bowley, As Money Launderers Buy Dalis, US Looks at Lifting the Veil on Art Sales, New York Times (June 19, 2021), available at https://www.nytimes.com/2021/06/19/arts/design/money-laundering-art-market.html. ↑
2. Blake Konkol, Lifting the Veil: What Are the Due Diligence Requirements for the Art Market in the United States?, Center for Art Law (July 26, 2022), available at https://itsartlaw.org/2022/07/26/lifting-the-veil-what-are-the-due-diligence-requirements-for-the-art-market-in-the-united-states/. ↑
3. Id. ↑
4. Graham Bowley, As Money Launderers Buy Dalis, US Looks at Lifting the Veil on Art Sales, New York Times (June 19, 2021), available at https://www.nytimes.com/2021/06/19/arts/design/money-laundering-art-market.html. ↑
5. RAM Initiative, RESPONSIBLE ART MARKET, https://www.responsibleartmarket.org/about-ram/ram-initiative/. ↑
6. Art Transaction Due Diligence Toolkit, RESPONSIBLE ART MARKET, https://www.responsibleartmarket.org/guidelines/art-transaction-due-diligence-toolkit/#downloads ↑
7. Art Market Intermediaries Toolkit, RESPONSIBLE ART MARKET, https://www.responsibleartmarket.org/guidelines/art-market-intermediaries-toolkit/ ↑
8. Elizabeth Weaver, Dealer or Agent and Why it Matters, Art Antiquity and Law (2011). ↑
9. Id. ↑
10. Id. ↑
11. Id. ↑
12. Robin Pogrebin, et al., Soaring Art Market Attracts a New Breed of Advisers for Collectors, New York Times, (Aug., 8, 2023), available at https://www.nytimes.com/2015/08/23/arts/design/soaring-art-market-attracts-a-new-breed-of-advisers-for-collectors.html. ↑
13. Graham Bowley, Jury Finds Sotheby’s Did Not Help in Any Fraud of Russian Oligarch,The New York Times (Jan. 30, 2024), available at https://www.nytimes.com/2024/01/30/arts/sothebys-art-fraud-trial.html. ↑
14. Colin Moynihan, At Trial, Sotheby’s Says Russian Oligarch Was Sloppy in Buying Art, New York Times (2024), available at https://www.nytimes.com/2024/01/10/arts/rybolovlev-sothebys-art-fraud-trial.html. ↑
15. Sam Knight, The Bouvier Affair, The New Yorker, (Jan. 31, 2016), available at https://www.newyorker.com/magazine/2016/02/08/the-bouvier-affair. ↑
16. Irina Malkova, The saga of Russia’s art-collecting oligarch and his new corruption woes in Monaco, The Bell (Nov. 10, 2018), available at https://en.thebell.io/the-saga-of-russia-s-art-collecting-oligarch-and-his-new-corruption-woes-in-monaco/. ↑
17. Antoine Harari, The Fox and the Oligarch, Heidi News (Dec. 1, 2020), available at https://www.heidi.news/explorations/the-fox-and-the-oligarch-the-incredible-bouvier-vs-rybolovlev-case/the-fox-and-the-oligarch. ↑
18. Id. ↑
19. Id. ↑
20. Graham Bowley, Jury Finds Sotheby’s Did Not Help in Any Fraud of Russian Oligarch,The New York Times (Jan. 30, 2024), available at https://www.nytimes.com/2024/01/30/arts/sothebys-art-fraud-trial.html. ↑
21. Scott Reyburn, Five Years Since the $450m Salvator Mundi Sale: A First-hand Account of the Nonsensical Auction, The Art Newspaper, (Nov. 15, 2022), available at https://www.theartnewspaper.com/2022/11/15/five-years-since-the-450m-salvator-mundi-sale-a-first-hand-account-of-the-nonsensical-auction ↑
22. Graham Bowley, Jury Finds Sotheby’s Did Not Help in Any Fraud of Russian Oligarch,The New York Times (Jan. 30, 2024), available at https://www.nytimes.com/2024/01/30/arts/sothebys-art-fraud-trial.html. ↑
23. Observed during Samuel Valette’s cross examination in trial on January 8th, 2024. ↑
24. Vincent Noce, Dmitry Rybolovlev and Yves Bouvier Settle Nine-year Legal Feud, The Art Newspaper, (Dec. 8, 2023), available at https://www.theartnewspaper.com/2023/12/08/dmitry-rybolovlev-and-yves-bouvier-settle-nine-year-feud. ↑
25. Id. ↑
26. Plaintiff’s Compl., Accent Delight International Ltd. v. Sotheby’s Inc., 18-cv-09011 (S.D.N.Y. Oct. 10, 2018). Feb. 1, 2024). ↑
27. Accent Delight International Ltd. v. Sotheby’s Inc., 18-cv-09011 (S.D.N.Y. Feb. 1, 2024). ↑
28. Sotheby’s About Us, available at https://www.sothebys.com/en/about?locale=en. ↑
29. Graham Bowley, Jury Finds Sotheby’s Did Not Help in Any Fraud of Russian Oligarch,The New York Times (Jan. 30, 2024), available at https://www.nytimes.com/2024/01/30/arts/sothebys-art-fraud-trial.html. ↑
30. Graham Bowley, At Art Fraud Trial, Sotheby’s Is Pressed on Role in Sales to Russian Oligarch, The New York Times (Jan. 17, 2024), available at https://www.nytimes.com/2024/01/17/arts/art-fraud-sothebys-russian-oligarch.html. ↑
31. Observed during Samuel Valette’s cross examination in trial on January 22nd, 2024. ↑
32. Josh Russel, Russian Billionaire Dmitry Rybolovlev Testifies in Sotheby’s trial, Courthouse News Service (Jan. 12, 2024), available at https://www.courthousenews.com/russian-billionaire-dmitry-rybolovlev-testifies-in-sothebys-trial/. ↑
33. Accent Delight Int’l Ltd. v. Sotheby’s & Sotheby’s Inc., No. 18-CV-9011 (S.D.N.Y. June 14, 2021). ↑
34. Courtesy of Arnold & Porter LLP ↑
35. Accent Delight Int’l Ltd. v. Sotheby’s & Sotheby’s Inc., No. 18-CV-9011 (S.D.N.Y. June 14, 2021). ↑
36. Colin Moynihan, At Trial, Sotheby’s Says Russian Oligarch Was Sloppy in Buying Art, New York Times (2024), available at https://www.nytimes.com/2024/01/10/arts/rybolovlev-sothebys-art-fraud-trial.html. ↑
37. Id. ↑
38. Plaintiff withdrew its aiding and abetting claim for the auction Modigliani’s Tete on January 26th, 2024, however the jury still considered this claim. ↑
39. Note, Plaintiff won nominal damages of $1.00 on their breach of contract claim against Sotheby’s in 2017, for the auction house violating their tolling agreement, separate from claims of aiding and abetting. ↑
40. See more: Measuring the Cost of Civil Litigation: Findings from a Survey of Trial Lawyers, VOIR DIRE, (2013), available at https://www.ncsc.org/__data/assets/pdf_file/0035/27989/measuring-cost-civil-litigation.pdf. ↑
41. Statement given by Arnold & Porter LLP on February 2, 2024 when contacted by CAL. ↑
42. Classement de la Procédure Dirigée Contre Yves BOUVIER, République et canton de Genève, (Dec. 18, 2023), available at https://justice.ge.ch/fr/actualites/classement-de-la-procedure-dirigee-contre-yves-bouvier. ↑
43. President Obama Nominates Four to the United States District Court, White House: Office of the Press Secretary (June 7, 2011), available at https://obamawhitehouse.archives.gov/the-press-office/2011/06/07/president-obama-nominates-four-united-states-district-court. ↑

Additional Suggested Readings:

• Book Review: “The Bouvier Affair: A True Story” (2019), available at https://itsartlaw.org/2019/09/25/book-review-the-bouvier-affair-a-true-story-2019/.
• List of articles published about the case:
  • The Art Newspaper, Sotheby’s and Rybolovlev’s lawyers paint contrasting pictures of culpability in fraud trial’s closing arguments
  • Artforum, Dmitry Rybolovlev Loses Fraud Case Against Sotheby’s – Artforum Blue-chip auction house Sotheby’s on January 30 was cleared of charges that it had aided an independent dealer in defrauding Russian…
  • https://news.artnet.com/art-world/yves-bouvier-rybolovlev-dispute-settled-2406832
  • https://www.economist.com/culture/2024/01/31/the-sothebys-trial-revealed-the-art-markets-unsavoury-practices