MEI Fields Designs Ltd v Saffron Cards And Gifts Ltd & Anor
Decision date: 6 June 2018
Neutral citation: [2018] EWHC 1332 (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 was a copyright dispute where Mrs Mei Fields and her company MFD claimed Saffron Cards (and Mr Paul Steele) copied greeting-card designs. The court found Mrs Fields was the author and first owner (and that a handwritten 10 April 2012 document assigned her copyright to MFD), held certain post-licence-sale Group A cards infringed, found two Group B cards (COU002, COU004) infringed while most others did not, and held Mr Steele jointly and severally liable with Saffron. The defendants’ counterclaim was dismissed.
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 applies a multifactorial test to decide whether artistic works are created in the course of employment (considering contract terms, time/place, materials, direction, ability to refuse and integrality to the business) rather than any single determinative factor; it also accepts that a contemporaneous informal handwritten document can amount to an assignment when that construction fits the commercial context; and a sole director/shareholder who actively cooperates in and intends the company’s tortious acts can be liable as a joint tortfeasor.
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 includes observations that omissions from a CVA are not automatically evidence of fraud (fraud requires proper pleading/evidence), that IPEC litigants should narrow issues and avoid late-expanding pleadings, and that tribunals may disregard voluminous disclosed documents not relied on in witness evidence.