Conrad Lant v Plastic Head Music Distribution Limited & Anor
Decision date: 31 July 2025
Neutral citation: [2025] EWHC 1954 (IPEC)
Overall AI summary confidence: high
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: high
This case concerned disputed authorship, ownership and subsistence of copyright in six Venom artworks and two photographs used on the band's merchandise and records. The judge found Mr Bray authored and owned one logo (Venom Logo 1) but rejected his other ownership claims; Mr Lant was held to own five works (Venom Logo 2, Goat Head Lucifer, Sigil of Baphomet, Legions Logo and one more), while the At War with Satan design had no proved author and both parties' claims failed; both photographic counterclaims by Mr Bray were dismissed. Infringement and flagrancy issues were considered but relief (remedies) was reserved for a later hearing; no infringements were found to be flagrant.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: medium
Where contemporaneous documentation is sparse and witness recollections conflict, the court should base findings on available contemporaneous documents and a careful assessment of the reliability of oral testimony, giving cautious weight to memories that may have been affected by litigation; and for simple or low‑quality designs, originality (and thus subsistence of copyright) can be established by modest but free and creative choices by the author.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The judgment highlights that litigation can distort long‑past memories and that indicators such as self‑contradiction, shifting cases and late evidence undermine witness reliability; it also observes that simplicity or low artistic quality does not preclude originality and that flagrancy of infringement requires separate consideration.