SAS Institute Inc v World Programming Ltd

SAS Institute Inc v World Programming Ltd

WPL did not infringe SAS Institute's copyrights in the SAS Components or SAS Manuals by producing WPS, as copyright does not protect programming languages, interfaces, or functionality. WPL's use of the Learning Edition was protected by Article 5(3) of the Software Directive, and contractual restrictions to the contrary are void. Only the WPS Manual infringed the SAS Manuals to the extent previously determined; the WPS Guides did not infringe.

Parties
Claimant: SAS Institute Inc.; Defendant: World Programming Limited
Jurisdiction
England and Wales
Judgment Date
25 January 2013
Procedural Posture
Copyright Infringement and Breach of Contract / Post CJEU Preliminary Ruling, Final Judgment
Outcome
Claim dismissed except for partial infringement by WPS Manual.
Legal Topics
Copyright in Computer Programs, Copyright in Manuals, Software Directive Interpretation, Information Society Directive Interpretation, Programming Languages and Interfaces, Breach of Software Licence
Intellectual Property Copyright Law Contract Law Copyright in Computer Programs Copyright in Manuals Software Directive Interpretation Information Society Directive Interpretation Programming Languages and Interfaces +1 more

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 3 Authorities cited 16 Party arguments 2
Sign in to unlock

Parties

SAS Institute Inc.

Claimant

World Programming Limited

Defendant

Procedural Posture

Copyright Infringement and Breach of Contract / Post CJEU Preliminary Ruling, Final Judgment

Legal Issues

  1. 1 Whether copyright in computer programs protects programming languages, interfaces, and functionality
  2. 2 Whether SAS Language and SAS data file formats are copyright works
  3. 3 Whether WPL infringed copyright in SAS Components and SAS Manuals

Ratio Decidendi

WPL did not infringe SAS Institute's copyrights in the SAS Components or SAS Manuals by producing WPS, as copyright does not protect programming languages, interfaces, or functionality. WPL's use of the Learning Edition was protected by Article 5(3) of the Software Directive, and contractual restrictions to the contrary are void. Only the WPS Manual infringed the SAS Manuals to the extent previously determined; the WPS Guides did not infringe.

Court Disposition

Claim dismissed except for partial infringement by WPS Manual.

Orders

  • WPL found to have infringed SAS Manuals only to the extent previously determined in respect of the WPS Manual.
  • All other claims by SAS Institute dismissed.