Lucasfilm Ltd & Ors v Ainsworth & Anor

Lucasfilm Ltd & Ors v Ainsworth & Anor

The stormtrooper helmet and armour are not sculptures under UK copyright law as they are primarily utilitarian props lacking the intrinsic artistic purpose required; UK courts lack subject-matter jurisdiction to enforce US copyright for acts done in the UK; the US default judgment is not enforceable in the UK as Ainsworth was not present in the US; and any copyright in Ainsworth's work was impliedly assigned to Lucasfilm.

Parties
Appellant/claimant: Lucasfilm Limited; Appellant/claimant: Star Wars Productions Limited; Appellant/claimant: Lucasfilm Entertainment Company Limited; Respondent/defendant: Andrew Ainsworth; Respondent/defendant: Shepperton Design Studios Limited
Jurisdiction
England and Wales
Judgment Date
16 December 2009
Procedural Posture
Civil Appeal / Court of Appeal Judgment on Appeal and Cross Appeal
Outcome
Appeal dismissed; cross-appeal allowed in part
Legal Topics
Copyright, Sculpture Definition, Jurisdiction Over Foreign Copyright, Enforcement of Foreign Judgments, Implied Assignment of Copyright
Intellectual Property Conflict of Laws Copyright Sculpture Definition Jurisdiction Over Foreign Copyright Enforcement of Foreign Judgments Implied Assignment of Copyright

Case Brief

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Parties

Lucasfilm Limited

Appellant/claimant

Star Wars Productions Limited

Appellant/claimant

Lucasfilm Entertainment Company Limited

Appellant/claimant

Andrew Ainsworth

Respondent/defendant

Shepperton Design Studios Limited

Respondent/defendant

Procedural Posture

Civil Appeal / Court of Appeal Judgment on Appeal and Cross Appeal

Legal Issues

  1. 1 Whether the stormtrooper helmet and armour are 'sculptures' under UK copyright law
  2. 2 Whether UK courts have subject-matter jurisdiction to enforce US copyright law for acts done in the UK
  3. 3 Whether a US default judgment for copyright infringement is enforceable in the UK

Ratio Decidendi

The stormtrooper helmet and armour are not sculptures under UK copyright law as they are primarily utilitarian props lacking the intrinsic artistic purpose required; UK courts lack subject-matter jurisdiction to enforce US copyright for acts done in the UK; the US default judgment is not enforceable in the UK as Ainsworth was not present in the US; and any copyright in Ainsworth's work was impliedly assigned to Lucasfilm.

Court Disposition

Appeal dismissed; cross-appeal allowed in part

Orders

  • No UK copyright infringement by Ainsworth; no injunction for UK acts
  • No enforcement of US copyright or US judgment in UK