moment, whatever may be our hopes for a change. That these pictures had their worth
and their success is sufficiently shown by the desire to reproduce them without
regard to the plaintiffs’ rights.- Simplicity is irrelevant to copyrightability
British Northrop Ltd v. Texteam Blackburn Ltd [1974] R.P.C. 57 (U.K.: High
Court)[The plaintiff had a catalogue containing drawings of spare parts for its
machinery. The defendant manufactured parts copied from the catalogue. The
plaintiff sued for copyright infringement. The defendant denied that there was
any copyright in the drawings of the parts.]MR JUSTICE MEGARRY:The [Copyright Act 1956 (U.K.)] merely provides ... that “’drawing’ includes any diagram, map,
chart or plan”, and so prima facieif there is anything which can fairly be called a diagram, it is
a drawing and may be the subject of copyright. It may indeed be that some thing may be drawn
which cannot fairly be called a diagram or a drawing of any kind: a single straight line drawn
with the aid of a ruler would not seem to me a very promising subject for copyright. But, apart
from cases of such barren and naked simplicity as that, I should be slow to exclude drawings
from copyright on the mere score of simplicity. I do not think that the mere fact that a drawing
is of an elementary and commonplace article makes it too simple to be the subject to copyright.In this case ...I accept that some of [the drawings] are indeed simple. They include a rivet, a
screw, a stud, a bolt, a metal bar, a length of wire with a thread cut at one end, a length of cable
with nipples at each end, a block of leather, a washer and a collar. They are all carefully drawn
to scale, with precise dimensions, and I cannot extract from the statute any indication that these
drawings should not be able to qualify for copyright. If simplicity were a disqualification, at
some point there would come enough complexity to qualify. It is not that I am unable to see
exactly where the Act draws the line: it is that I cannot see that there is any intention to drawn
any line at all.NOTE:We shall now examine the various categories of work to consider their
extent and limits.- Literary work
University of London Press Ltd v. University Tutorial Press Ltd [1916] 2 Ch.
601 (U.K.: High Court)[The plaintiff sued the defendant for infringing copyright in examination papers
in mathematics. The defendant denied that examination papers were “literary
works”.]MR JUSTICE PETERSON:It may be difficult to define “literary work” as used in this Act, but it seems to be plain that it is
not confined to “literary work” in the sense in which that phrase is applied, for instance, to
Meredith’s novels and the writings of Robert Louis Stevenson. In speaking of such writings as(^56) literary works, one thinks of the quality, the style, and the literary finish which they exhibit.