Sony/ATV Music Publishing LLC & Anor v WPMC Ltd & Anor

Sony/ATV Music Publishing LLC & Anor v WPMC Ltd & Anor

No binding contract was concluded as negotiations were subject to contract and approval; proprietary estoppel does not apply due to subject to contract stipulation; the use of the Copyright Works in the Documentary is not fair use under US law due to excessive reproduction, only partial transformation, and likely market harm.

Parties
Claimant: SONY/ATV MUSIC PUBLISHING LLC; Claimant: SONY/ATV MUSIC PUBLISHING (UK) LIMITED; Defendant: WPMC LIMITED; Defendant: IAMBIC MEDIA LIMITED (IN LIQUIDATION)
Jurisdiction
England and Wales
Judgment Date
01 July 2015
Procedural Posture
Copyright Infringement / Final Judgment
Outcome
SATV succeed in their claims for infringement (or threatened infringement) of the UK and US copyrights in the Copyright Works.
Legal Topics
Copyright Infringement, Fair Use, Proprietary Estoppel, Collateral Contract, Synchronisation Licence
Intellectual Property Contract Law Copyright Infringement Fair Use Proprietary Estoppel Collateral Contract Synchronisation Licence

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Parties

SONY/ATV MUSIC PUBLISHING LLC

Claimant

SONY/ATV MUSIC PUBLISHING (UK) LIMITED

Claimant

WPMC LIMITED

Defendant

IAMBIC MEDIA LIMITED (IN LIQUIDATION)

Defendant

Procedural Posture

Copyright Infringement / Final Judgment

Legal Issues

  1. 1 Whether a binding collateral contract for a synchronisation licence was concluded
  2. 2 Whether proprietary estoppel prevents SATV from denying a licence
  3. 3 Whether exploitation of the Documentary in the USA constitutes fair use under US copyright law

Ratio Decidendi

No binding contract was concluded as negotiations were subject to contract and approval; proprietary estoppel does not apply due to subject to contract stipulation; the use of the Copyright Works in the Documentary is not fair use under US law due to excessive reproduction, only partial transformation, and likely market harm.

Court Disposition

SATV succeed in their claims for infringement (or threatened infringement) of the UK and US copyrights in the Copyright Works.

Orders

  • Declaration of copyright infringement
  • No synchronisation licence to WPMC