Ultra Marketing (UK) Ltd & Anor v Universal Components Ltd [2004] EWHC 468 (Ch) (12 March 2004)

Ultra Marketing (UK) Ltd & Anor v Universal Components Ltd [2004] EWHC 468 (Ch) (12 March 2004)

The 1976 drawing was an original artistic work, but the defendant's designs were independently created and did not copy the visual features of the 1976 drawing. The similarities were attributable to commonplace ideas and technical constraints, not to copying. There was no infringement of copyright.

Citation
[2004] EWHC 468 (Ch)
Parties
Claimant: Ultra Marketing (UK) Limited; Claimant: Thomas Alexander Scott; Defendant: Universal Components Limited
Jurisdiction
England and Wales
Judgment Date
12 March 2004
Procedural Posture
Copyright Infringement Claim / Final Judgment After Trial
Outcome
Claim dismissed
Legal Topics
Copyright, Artistic Works, Indirect Copying, Originality, Design Documents
Intellectual Property Copyright Artistic Works Indirect Copying Originality Design Documents

Case Brief

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Parties

Ultra Marketing (UK) Limited

Claimant

Thomas Alexander Scott

Claimant

Universal Components Limited

Defendant

Procedural Posture

Copyright Infringement Claim / Final Judgment After Trial

Legal Issues

  1. 1 Whether the 1976 drawing was an original artistic work entitled to copyright protection
  2. 2 Whether the defendant's products indirectly copied the claimant's 1976 drawing
  3. 3 Whether the similarities between the works raised a presumption of copying

Ratio Decidendi

The 1976 drawing was an original artistic work, but the defendant's designs were independently created and did not copy the visual features of the 1976 drawing. The similarities were attributable to commonplace ideas and technical constraints, not to copying. There was no infringement of copyright.

Court Disposition

Claim dismissed

Orders

  • Action dismissed
  • No finding of copyright infringement