Armstrong Watson LLP v Persons Unknown [2023] EWHC 1761 (KB) (11 July 2023)

Armstrong Watson LLP v Persons Unknown [2023] EWHC 1761 (KB) (11 July 2023)

The claimant was entitled to default judgment because the defendants failed to file a defence or engage with proceedings, the pleaded facts established a cause of action for breach of confidence, and the risk of further unlawful disclosure justified permanent injunctive relief and costs.

Citation
[2023] EWHC 1761 (KB)
Parties
Claimant: Armstrong Watson LLP; Defendant(s): Persons Unknown
Jurisdiction
England and Wales
Judgment Date
11 July 2023
Procedural Posture
Civil Breach of Confidence / Cybersecurity / Default Judgment Application for Final Injunction and Costs
Outcome
Default judgment for the claimant; permanent injunction granted; costs awarded to claimant.
Legal Topics
Breach of Confidence, Interim and Final Injunctions, Default Judgment, Cyberattack, Ransomware, Open Justice, Costs

Case Brief

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Parties

Armstrong Watson LLP

Claimant

Persons Unknown

Defendant(s)

Procedural Posture

Civil Breach of Confidence / Cybersecurity / Default Judgment Application for Final Injunction and Costs

  1. 1 Whether the claimant is entitled to default judgment for breach of confidence against persons unknown following a cyberattack and threats of disclosure of confidential information
  2. 2 Whether permanent injunctive relief and costs should be granted in the absence of a defence

Ratio Decidendi

The claimant was entitled to default judgment because the defendants failed to file a defence or engage with proceedings, the pleaded facts established a cause of action for breach of confidence, and the risk of further unlawful disclosure justified permanent injunctive relief and costs.

Court Disposition

Default judgment for the claimant; permanent injunction granted; costs awarded to claimant.

Orders

  • Judgment entered against the defendants under CPR Part 12
  • Permanent injunctive relief restraining use, disclosure, or dealing with the confidential information and requiring deletion or delivery up