Edozo Ltd v Valos (UK) Ltd [2026] EWHC 93 (IPEC) (21 January 2026)

Edozo Ltd v Valos (UK) Ltd [2026] EWHC 93 (IPEC) (21 January 2026)

Copying the functionality, logic, or user steps of a computer program, without copying its source code or other protectable expression, does not infringe copyright in the program's source code. The law protects the expression of ideas (the code), not the ideas or functionality themselves. Therefore, allegations of indirect copying based solely on similarities in user steps or outputs do not disclose a reasonable cause of action for copyright infringement and must be struck out.

Citation
[2026] EWHC 93 (IPEC)
Parties
Claimant: Edozo Limited; Defendant: Valos (UK) Limited
Jurisdiction
England and Wales
Judgment Date
21 January 2026
Procedural Posture
Intellectual Property (copyright) Claim and Counterclaim / Interlocutory Application to Strike Out Parts of Defence and Counterclaim
Outcome
Application granted. Relevant parts of Defence and Counterclaim struck out.
Legal Topics
Copyright in Computer Programs, Idea/expression Dichotomy, Indirect Copying, Functionality and Copyright, Substantiality in Copyright Infringement
Intellectual Property Law Copyright in Computer Programs Idea/expression Dichotomy Indirect Copying Functionality and Copyright Substantiality in Copyright Infringement

Case Brief

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Parties

Edozo Limited

Claimant

Valos (UK) Limited

Defendant

Procedural Posture

Intellectual Property (copyright) Claim and Counterclaim / Interlocutory Application to Strike Out Parts of Defence and Counterclaim

Legal Issues

  1. 1 Whether copying the functionality (steps or logic) of a computer program, without copying its source code, constitutes infringement of copyright in the program's source code under UK law
  2. 2 Whether allegations of indirect copying based on similarities in user steps or outputs disclose a reasonable cause of action for copyright infringement

Ratio Decidendi

Copying the functionality, logic, or user steps of a computer program, without copying its source code or other protectable expression, does not infringe copyright in the program's source code. The law protects the expression of ideas (the code), not the ideas or functionality themselves. Therefore, allegations of indirect copying based solely on similarities in user steps or outputs do not disclose a reasonable cause of action for copyright infringement and must be struck out.

Court Disposition

Application granted. Relevant parts of Defence and Counterclaim struck out.

Orders

  • Those parts of the Defence and Counterclaim which allege indirect infringement of the literary copyright in the Original Valos Computer Program, the Subsequent Valos Computer Programs and the Valos Coded Prompts are struck out.