MEI Fields Designs Ltd v Saffron Cards And Gifts Ltd & Anor [2018] EWHC 1332 (IPEC) (06 June 2018)

MEI Fields Designs Ltd v Saffron Cards And Gifts Ltd & Anor [2018] EWHC 1332 (IPEC) (06 June 2018)

Mrs Fields designed the relevant cards outside the scope of her employment with Metropolis and was the first owner of copyright. Alternatively, there was an agreement to the contrary that she would own the copyright. There was no trust in favour of Metropolis, as the directors/shareholders agreed Mrs Fields would own the copyright. Junior designers’ digitisation was mechanical and did not amount to joint authorship. MFD is the owner of copyright in the Works. Defendants infringed copyright by producing and selling cards after licence termination and by copying designs. Mr Steele is jointly and severally liable as he directed and procured the infringing acts.

Citation
[2018] EWHC 1332 (IPEC)
Parties
Claimant: Mei Fields Designs Limited; First Defendant: Saffron Cards and Gifts Limited; Second Defendant: Paul James Steele
Jurisdiction
England and Wales
Judgment Date
06 June 2018
Procedural Posture
Copyright Infringement Claim / Final Judgment After Trial
Outcome
Claim allowed in favour of MFD; Defendants found liable for copyright infringement.
Legal Topics
Copyright Ownership, Employment and Copyright, Joint Authorship, Director Fiduciary Duties, Assignment of Copyright, Infringement of Copyright, Licence Agreements
Intellectual Property Copyright Law Copyright Ownership Employment and Copyright Joint Authorship Director Fiduciary Duties Assignment of Copyright Infringement of Copyright +1 more

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Parties

Mei Fields Designs Limited

Claimant

Saffron Cards and Gifts Limited

First Defendant

Paul James Steele

Second Defendant

Procedural Posture

Copyright Infringement Claim / Final Judgment After Trial

Legal Issues

  1. 1 Whether MFD is the sole owner of copyright in the Works or whether Metropolis is a joint or sole owner
  2. 2 Whether the Works were created within the scope of Mrs Fields’ employment with Metropolis
  3. 3 Whether Mrs Fields held copyright on trust for Metropolis due to her directorship

Ratio Decidendi

Mrs Fields designed the relevant cards outside the scope of her employment with Metropolis and was the first owner of copyright. Alternatively, there was an agreement to the contrary that she would own the copyright. There was no trust in favour of Metropolis, as the directors/shareholders agreed Mrs Fields would own the copyright. Junior designers’ digitisation was mechanical and did not amount to joint authorship. MFD is the owner of copyright in the Works. Defendants infringed copyright by producing and selling cards after licence termination and by copying designs. Mr Steele is jointly and severally liable as he directed and procured the infringing acts.

Court Disposition

Claim allowed in favour of MFD; Defendants found liable for copyright infringement.

Orders

  • Declaration that MFD is the owner of copyright in the Works
  • Injunction restraining Defendants from further infringement