SAS Institute Inc v World Programming Ltd [2013] EWHC 69 (Ch) (25 January 2013)

SAS Institute Inc v World Programming Ltd [2013] EWHC 69 (Ch) (25 January 2013)

Copyright in computer programs does not protect programming languages, data file formats, or functionality from being copied. The SAS Language and data file formats were not pleaded or proved as independent copyright works. WPL did not infringe SAS Institute's copyrights in the SAS Components or SAS Manuals by developing WPS. Use of the Learning Edition outside licence terms did not constitute copyright infringement or breach of contract except possibly in one instance, as Article 5(3) of the Software Directive permitted observation, study, and testing within the scope of the licence.

Citation
[2013] EWHC 69 (Ch)
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 Claim / Post Trial Judgment Following CJEU Preliminary Ruling
Outcome
Claim dismissed except as to admitted or previously determined infringements.
Legal Topics
Copyright Protection of Computer Programs, Copyright Protection of Programming Languages and Data Formats, Scope of Software Copyright Under EU Law, Breach of Software Licence Agreements, Reproduction of Substantial Part, Originality and Fixation in Copyright, Interpretation of EU Directives on Copyright
Intellectual Property Copyright Law Software Law Contract Law Copyright Protection of Computer Programs Copyright Protection of Programming Languages and Data Formats Scope of Software Copyright Under EU Law Breach of Software Licence Agreements +3 more

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Parties

SAS Institute Inc.

Claimant

World Programming Limited

Defendant

Procedural Posture

Copyright Infringement and Breach of Contract Claim / Post Trial Judgment Following CJEU Preliminary Ruling

Legal Issues

  1. 1 Whether copyright in computer programs protects programming languages, data file formats, and functionality from being copied
  2. 2 Whether the SAS Language and SAS data file formats are protectable as independent copyright works
  3. 3 Whether WPL infringed copyright in the SAS Components or SAS Manuals by developing WPS

Ratio Decidendi

Copyright in computer programs does not protect programming languages, data file formats, or functionality from being copied. The SAS Language and data file formats were not pleaded or proved as independent copyright works. WPL did not infringe SAS Institute's copyrights in the SAS Components or SAS Manuals by developing WPS. Use of the Learning Edition outside licence terms did not constitute copyright infringement or breach of contract except possibly in one instance, as Article 5(3) of the Software Directive permitted observation, study, and testing within the scope of the licence.

Court Disposition

Claim dismissed except as to admitted or previously determined infringements.

Orders

  • WPL has not infringed SAS Institute's copyrights in the SAS Components by producing WPS.
  • WPL has not infringed SAS Institute's copyright in the SAS Manuals by producing or testing WPS.