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Walter v Lane

[1900] AC 539

Case summary last updated at 29/01/2020 15:15 by the Oxbridge Notes in-house law team.

Judgement for the case Walter v Lane

An Earl gave public speeches on 5 occasions. Reporter from newspaper took down speeches in shorthand and later transcribed them. D published book which included Earl’s speeches taken mainly from the reports published in newspaper. Newspaper brought action for breach of copyright.

·        Copyright has nothing to do with or literary/artistic merits of the author.
Ø  Copyright simply requires that A shall not avail himself of B’s skill, labour and expense by copying the end product.
·        To be ‘author’, written work in question must have necessitated more than mere skill of knowing how to write.
Ø  i.e. must require intellectual skill.
·        Production of report required more than mere act of writing; e.g.:
Ø  ability to write shorthand
Ø  subsequent transcribing, with punctuation and revisions added
Ø  memory and judgment of reporter
·        Thus on facts, reporters for paper were authors.

Walter v Lane crops up in following areas of law