Aga Rangemaster Group Ltd v UK Innovations Group Ltd & Anor

Aga Rangemaster Group Ltd v UK Innovations Group Ltd & Anor

UKIG's marketing and sale of converted AGA cookers using the term 'eControl AGA' and related materials was likely to give customers the false impression of a commercial connection with AGA, providing AGA with legitimate reasons to oppose further dealings under s12(2) of the Trade Marks Act 1994. The judge's findings on the impression created were rational and supported by evidence. On copyright, the control panel was not an artistic work for the purposes of s51 CDPA 1988, so UKIG had a defence to copyright infringement.

Parties
Claimant/respondent: AGA Rangemaster Group Ltd; First Defendant/appellant: UK Innovations Group Ltd; Second Defendant: Michael Patrick McGinley
Jurisdiction
England and Wales
Judgment Date
15 December 2025
Procedural Posture
Civil Appeal / Court of Appeal Judgment on Appeal From High Court
Outcome
Appeal dismissed; cross-appeal dismissed
Legal Topics
Trade Mark Infringement, Copyright Infringement, Exhaustion of Rights, Legitimate Reasons to Oppose Further Dealings, Impression of Commercial Connection, Section 12 Trade Marks Act 1994, Section 51 Copyright, Designs and Patents Act 1988
Intellectual Property Commercial Law Trade Mark Infringement Copyright Infringement Exhaustion of Rights Legitimate Reasons to Oppose Further Dealings Impression of Commercial Connection Section 12 Trade Marks Act 1994 +1 more

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Parties

AGA Rangemaster Group Ltd

Claimant/respondent

UK Innovations Group Ltd

First Defendant/appellant

Michael Patrick McGinley

Second Defendant

Procedural Posture

Civil Appeal / Court of Appeal Judgment on Appeal From High Court

Legal Issues

  1. 1 Whether UKIG's marketing and sale of converted AGA cookers infringed AGA's trade marks despite exhaustion defence under s12 Trade Marks Act 1994
  2. 2 Whether UKIG's use of 'eControl AGA' created a false impression of commercial connection with AGA
  3. 3 Whether UKIG infringed AGA's copyright in control panel graphics or had a defence under s51 CDPA 1988

Ratio Decidendi

UKIG's marketing and sale of converted AGA cookers using the term 'eControl AGA' and related materials was likely to give customers the false impression of a commercial connection with AGA, providing AGA with legitimate reasons to oppose further dealings under s12(2) of the Trade Marks Act 1994. The judge's findings on the impression created were rational and supported by evidence. On copyright, the control panel was not an artistic work for the purposes of s51 CDPA 1988, so UKIG had a defence to copyright infringement.

Court Disposition

Appeal dismissed; cross-appeal dismissed

Orders

  • UKIG's appeal dismissed; judgment for AGA on trade mark claim upheld
  • AGA's cross-appeal on copyright dismissed; UKIG entitled to s51 defence