SAS Institute Inc v World Programming Ltd [2010] EWHC 1829 (Ch) (23 July 2010)

SAS Institute Inc v World Programming Ltd [2010] EWHC 1829 (Ch) (23 July 2010)

WPL did not infringe copyright in SAS Components by emulating functionality, as copyright does not protect ideas or methods of operation; WPL did not infringe copyright in SAS Manuals by using them to determine external behaviour; WPL's documentation did not reproduce a substantial part of SAS Manuals; WPL's use of Learning Edition for performance testing was not proven to breach contract or copyright.

Citation
[2010] EWHC 1829 (Ch)
Parties
Claimant: SAS Institute Inc.; Defendant: World Programming Limited
Jurisdiction
England and Wales
Judgment Date
23 July 2010
Procedural Posture
Copyright and Contract Dispute / High Court Trial, Judgment
Outcome
Claim dismissed
Legal Topics
Copyright in Computer Programs, Copyright in Manuals, Reverse Engineering, Software Interoperability, Breach of Contract, European Software Directive
Intellectual Property Contract Law European Law Copyright in Computer Programs Copyright in Manuals Reverse Engineering Software Interoperability Breach of Contract +1 more

Case Brief

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Parties

SAS Institute Inc.

Claimant

World Programming Limited

Defendant

Procedural Posture

Copyright and Contract Dispute / High Court Trial, Judgment

Legal Issues

  1. 1 Whether WPL infringed copyright in SAS Components by emulating functionality
  2. 2 Whether WPL infringed copyright in SAS Manuals by copying content
  3. 3 Whether WPL breached contract by using SAS Learning Edition contrary to licence

Ratio Decidendi

WPL did not infringe copyright in SAS Components by emulating functionality, as copyright does not protect ideas or methods of operation; WPL did not infringe copyright in SAS Manuals by using them to determine external behaviour; WPL's documentation did not reproduce a substantial part of SAS Manuals; WPL's use of Learning Edition for performance testing was not proven to breach contract or copyright.

Court Disposition

Claim dismissed

Orders

  • No injunction granted
  • No damages awarded