Edozo Limited v Valos (UK) Limited
Decision date: 21 January 2026
Neutral citation: [2026] EWHC 93 (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
Edozo and Valos, competitors in property valuation software, disputed whether Edozo had indirectly infringed Valos's computer program copyrights by reproducing the user-facing sequence of interactions ("Valos Steps") without access to Valos's source code. The court held that the Valos Steps form part of the program's functionality and are not expression of the author's intellectual creation in the source code, so reproducing those Steps cannot, as pleaded, amount to indirect infringement of Valos's source code. Accordingly, the parts of Valos's Defence and Counterclaim alleging indirect infringement of the Original and Subsequent Valos Computer Programs and the Valos Coded Prompts were struck out.
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: high
The judgment identifies and applies the principle that copyright in a computer program protects the expression embodied in the source code (the author's skill, judgment and labour in devising that code), not the program's functionality or the external sequence of user interactions it produces; therefore reproducing a program's external behaviour or user-facing Steps does not, without more, constitute reproduction of the source-code expression and cannot found indirect copyright infringement of that source code.
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 judge noted that where intellectual creativity exists in user-facing steps, protection might instead be pursued by asserting separate literary or artistic copyright in those steps or by patent protection for inventive functionality, and that policy arguments favouring protection of invested effort in functionality do not alter the established idea/functionality versus expression boundary in copyright law.