Facts below. Was argued that as C had been commissioned to create databases, copyright in these was vested in D. Held:
· If C is commissioned to carry out work for D, in absence of express or implied agreement to contrary work belongs to C.
Ø Mere fact that C has been commissioned does not mean commissioner is entitled to the copyright
· However implied agreement to contrary may be found if it is reasonably necessary to give business efficacy to contract.