C, performer of an organ part in song “Whiter Shade of Pale”, claimed he was joint author of the song with D, band member who had originally composed song. C had composed a detailed organ solo, along with organ accompaniment for entire duration of 4 minute piece. Held:
· Organ solo was significant contribution to overall work.
Ø In that it was more than trivial.
· Organ solo was also an original contribution to overall work.
Ø in that it was:
i) the product of skill and labour.
ii) sufficiently different from piano part that D had originally composed.
· Therefore C was joint author of song.