Magmatic Ltd v PMS International Group Plc [2014] EWCA Civ 181 (28 February 2014)

Magmatic Ltd v PMS International Group Plc [2014] EWCA Civ 181 (28 February 2014)

The proper comparison for infringement of a registered design must include surface decoration and colour if they affect the overall impression; the Kiddee Case creates a different overall impression from the CRD and does not infringe.

Citation
[2014] EWCA Civ 181
Parties
Claimant/respondent: Magmatic Ltd; Defendant/appellant: PMS International Group Plc
Jurisdiction
England and Wales
Judgment Date
28 February 2014
Procedural Posture
Appeal / Court of Appeal Judgment
Outcome
Appeal allowed; finding of infringement reversed.
Legal Topics
Community Registered Design, Design Infringement, Scope of Protection, Interpretation of Design Registration

Case Brief

Summary, issues, holding and outcome

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Parties

Magmatic Ltd

Claimant/respondent

PMS International Group Plc

Defendant/appellant

Procedural Posture

Appeal / Court of Appeal Judgment

  1. 1 Whether the Kiddee Case infringes Community Registered Design No. 43427-0001
  2. 2 Proper scope and interpretation of the CRD
  3. 3 Whether surface decoration and colour should be considered in infringement analysis

Ratio Decidendi

The proper comparison for infringement of a registered design must include surface decoration and colour if they affect the overall impression; the Kiddee Case creates a different overall impression from the CRD and does not infringe.

Court Disposition

Appeal allowed; finding of infringement reversed.

Orders

  • The Kiddee Case does not infringe Community Registered Design No. 43427-0001.
  • Judgment of Arnold J set aside.