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Parody in English Law


4 October 2010

Parody means slightly different things in different contexts, but at its core it is a deliberate imitation, usually for comic effect. This article sets out an overview of English law’s approach to parody, with an emphasis on recent cases, and considers the application of domain name dispute rules to domains that host parody sites.

Parody in English copyright law

For a parody to succeed, it must be clear what is being parodied – and as this may be done by copying the original, copyright law is key to an understanding of parodies. It is often assumed that parody is exempted from the normal rules of copyright, and in some jurisdictions it is. For example, in Campbell v Acuff-Rose Music, 510 US 569 (1994) the US Supreme Court held that commercial parody could qualify as fair use. In assessing whether someone has made fair use of a copyright work, one should look at whether or not the use it was put to was transformative or not.

The English courts once also held that transformative works would not infringe copyright. This approach is exemplified by Younger J in Glyn v Weston Feature Film Company [1916] 1 Ch. 261, who held that there was a principle that “no infringement of the plaintiff's rights takes place where a defendant has bestowed such mental labour upon what he has taken and has subjected it to such revision and alteration as to produce an original result”.

However, this is no longer considered good law. In Schweppes v Wellingtons [1984] F.S.R. 210, Falconer J was asked to consider whether the defendants’ labels, which bore the word ‘Schlurppes’, infringed the claimant’s copyright in its Schweppes labels. The judge stated that the test was simple – was there reproduction of a substantial part of the claimant’s work? It was of no relevance whether or not a new work had been created. This approach was followed in Williamson Music Ltd v The Pearson Partnership Ltd (1987) F.S.R. 87.

When determining whether or not a ‘substantial part’ of a work has been copied, one must look at whether substantial use of the author’s skill and labour has been made, or whether or not what has been reproduced express the author’s own intellectual creation. In practice, the hurdle for direct textual reproduction is quite low, and following Case C-5/08 Infopaq International A/S v Danske Dagblades Forening [2009] ECR I-0000, it seems that even copying seven words could amount to copyright infringement. Copyright does not just cover words – as Lord Hoffman said in Designers Guild Ltd v Russell Williams (Textiles) Ltd [2001] 1 W.L.R. 2416,

“the original elements in the plot of a play or novel may be a substantial part, so that copyright may be infringed by a work which does not reproduce a single sentence of the original”.

However, it is trite law that copyright protects the expression of an idea, not an idea itself. In Baigent & Anor v The Random House Group Ltd [2007] EWCA Civ 247, it was claimed that The Da Vinci Code copied the theme of the claimants' earlier historical work, but the claimants failed to establish that The Da Vinci Code reproduced anything protected by copyright.

It could also in some circumstances be open to defendants to claim that the parody is fair dealing as it is used for the purposes of criticism or review, which is permitted under section 30 of the CDPA.

The Gowers Review, an independent review commissioned by the government and published in 2006, called for the government to create an exception to copyright for the purpose of caricature, parody or pastiche by 2008; and such an exception from copyright law is expressly permitted by the 2001 Information Society Directive (Art 5 (3) k). However, following a consultation, the UK’s Intellectual Property Office felt that a change would create uncertainty and prejudice rights holders, so it appears that law reform is unlikely, at least in the near future.

Copyright and online parodies – the difficulties of enforcement

Online parodies abound, and with many it is clear that they infringe copyright. However, despite rightsholders' best efforts, it can be very difficult to get the infringements down.

EU law provides that service providers are not liable for information they host, as long as (a) they do not have actual knowledge of the content, and (b) once they become aware they act expeditiously to take the information down. In practice, this often means that service providers usually remove allegedly infringing material first and ask questions later. But when the material is uploaded again, the rightsholder has to start the process again.

For example, a sequence from the 2004 film Downfall in which Hitler launches into a tirade about the Russian advance became an internet meme when it was resubtitled. A series of parodies and satires had Hitler ranting instead about being banned from Xbox Live, Michael Jackson’s death, or that he cannot get tickets to see Billy Elliot. Constantin Films, the rights owners, have tried to have the subtitled versions removed from YouTube and similar sites, apparently pursuant to the US Digital Millennium Copyright Act. But the take downs have not succeeded; as one video goes down, another is put up. The situation has reached the farcical stage whereby one of the more popular Downfall parodies is of Hitler ranting about the parodies, and demanding that they should be taken down.

In this case, the takedowns failed because by the time they were attempted, the videos in question had already become very popular. If you want to manage parodies, or indeed any content harmful to your brand, you need to actively manage your portfolio, monitor online use of your IP, and quickly identify and removing infringing works. Of course, it is worth asking the question – is the infringement doing you any harm, or is it just generating free viral publicity for your product?

The flip side of this for many businesses is – if you are seeking to parody something, check that, to the extent that you are using it, you have permission. Soon after the government rushed through the Digital Economy Act before the 2010 general election, both political parties were alleged to have infringed a television production company’s copyright by superimposing an image of David Cameron on to one of Gene Hunt from the BBC television series Ashes to Ashes.

Brand parody

‘Brand parody’ is a further form of parody, and is often a euphemistic way to say that your advertising or get up gives a nod and a wink to another more famous brand.

A classic example was United Biscuits v Asda [1997] R.P.C. 513. The claimant, who made Penguin biscuits, sued Asda for passing off and trade mark infringement after Asda launched its own ‘Puffin’ biscuits, which like the Puffin biscuits featured a dark seabird and black lettering. The court found that Asda had “miscalculated the degree of “challenge” or “matching” or “parody” that was tolerable without the product being actually deceptive”, and their sale of the Puffin biscuits amounted to passing off. However, Asda were not found to have infringed United Biscuits’ trade marks (except very briefly), and a number of United Biscuits’ marks were revoked.

In a recent judgment, Specsavers International Healthcare Ltd and others v Asda Stores Ltd [2010] EWHC 2035 (Ch), Asda have again been found to have sailed too close to the wind with a brand parody, and were found liable for trade mark infringement – but only just.

Asda had deliberately set out to parody Specsavers’ advertisements, trying to get as close to Specsavers’ branding as possible without infringing.

Specsavers claimed that three aspects of this campaign infringed their trade marks. Firstly, they claimed that the Asda Opticians logo infringed certain of their device marks. Secondly, they claimed that the straplines “Be a real spec saver at Asda” and “Spec savings at ASDA” infringed their word mark SPECSAVERS. All the trade marks were CTMs.

The court held that there was no infringement under 9 (1) (b) of the Trade Mark Regulation, because Asda’s logos and straplines were not confusingly similar to Specsavers’ marks. Asda could show little evidence of actual confusion, and the typical consumer would realise that there was a play on words, and would not be confused about origin.

However, in respect of 9 (1) (c) infringement – taking unfair advantage - the court found differently. There had been suggestions following the decision in Whirlpool v Kenwood [2010] RPC 2 that 9 (1) (c) infringement could only occur when a small brand tried to piggy back on a large brand – but the judge in this case rejected that interpretation.

The court found that the strapline “Be a real spec saver at Asda” took unfair advantage of Specsavers’ trade mark, and rode on that mark’s coat tails.

In contrast, no unfair advantage was found in respect of “Spec savings at ASDA”, as the court held that the link with Specsavers’ marks was much weaker, saying that it did not use Specsavers’ reputation to get a leg up. The judge also found no infringement in respect of the logo, though he did say that evidence that Asda had sought to live dangerously had made the issue more complicated for him. The court also rejected the passing off claim.

As a sideline, Specsavers’ device mark that did not contain the word mark ‘Specsavers’ was revoked for non-use. Specsavers had only ever used it in conjunction with the word Specsavers, and the court held that the addition of the word across the logo altered the distinctive character of the mark.

It is also interesting that Asda did not raise the Comparative Advertising Directive 2006/114/EC as a defence. The directive permits comparisons in advertising when an advertisement complies with the provisions of Article 4, which prohibits misleading, unfair and denigrating advertisements. It might have been open to Asda to argue that in so far as its advertisement did take advantage of Specsavers’ mark, it did so by drawing a comparison between Asda and Specsavers – and that, so long as the advertisement complied with Article 4, it was permitted.

Spoof diaries

There have also been a couple of interesting cases before the English courts which involved neither copyright not trade marks. Instead, they involved spoof diaries.

Alan Clark, the famous Tory MP, successfully published his diaries in 1993. In the run up to the 1997 General Election, the Evening Standard published a series of parody articles titled ‘Alan Clark’s Secret Election Diary’. Clark took umbrage to this and sued for passing off and false attribution – and the judge found in his favour. Clark v Associated Newspapers [1998] R.P.C. 26 turned on the judge’s finding of fact that impression given by the photograph of Claimant beside his name at the heading of the article was not sufficiently neutralised by the various counter-indications throughout the article that the work was in fact a parody – which included the real author’s name in capital letters near the start of every article, and the presence of ‘secret’ in the articles’ titles. With a different judge, it is possible that the case would have been decided differently.

Spoof diaries were again before the English courts in Elton John v Guardian News & Media Ltd [2008] EWHC 3066 (QB). The spoof entry suggested that Elton John spent most of the income for a charity ball on the ball itself, and Elton John sued for defamation. Unlike the Alan Clark case, Elton John accepted that no reasonable reader would have thought that he had written the article himself. In this instance, the court held that readers would understand that the article was a joke, and that it was therefore not defamatory.

Domain name complaints

Finally, we take a look at the approach taken to parodies in domain name dispute proceedings.

Disputes for the top level domains .com, .net and .org are governed by the Universal Dispute Resolution Policy (UDRP). Disputes for .co.uk, .org.uk and .net.uk domains are governed by Nominet’s Dispute Resolution Service (DRS).

There has not been a contested complaint regarding a parody site under the DRS procedure. In starbuckscoffee.co.uk DRS 02087, the website located at the domain name declared that it was a ‘form of cultural and political criticism and satire’. However, no proper response was filed, so the decision can not be said to provide a thorough analysis of the rights of a satirist or a parodist to a domain name.

We therefore need to look at the policy itself. To succeed in a DRS complaint, a party must show that they have rights in a name, and that, in the hands of the other party, the domain registration is an abusive registration. One of the factors that may evidence that a registration is abusive is if the domain is used to confuse people or businesses into believing that the domain is connected with the complainant. However, the policy also says that fair use may include sites operated solely in tribute to or in criticism of a person or business.

As parody sites may confuse visitors, a registration of a domain name identical to someone's trading name may be an abusive registration. In guidestar.co.uk DRS 02193, the appeals panel held that deliberate impersonation would rarely be acceptable, and in that case the domain registration was abusive because “it was calculated to cause confusion and manifestly involved taking unfair advantage of the Complainant’s rights.” Under the DRS, therefore, parody sites may struggle to show they are not abusive.

In contrast, under the UDRP, a parody site recently established that it was not abusive.

In sutherlandinstitute.com D2009-0693, a conservative think tank, launched a UDRP complaint about the domain which parodied its own website sutherlandinstitute.org, but which, though reminiscent of the genuine site, did state that it was a parody site and was not affiliated with the Sutherland Institute.

To succeed in a UDRP complaint, you need to prove:

(i) your domain name is identical or confusingly similar to a trademark or service mark in which the complainant has rights; and

(ii) you have no rights or legitimate interests in respect of the domain name; and

(iii) your domain name has been registered and is being used in bad faith.

The panel unsurprising found that the Sutherland Institute had rights in their name.

The panel also found that the parody was not a legitimate interest. The Sutherland Institute's trade mark was not itself being parodied “because there is no transformation of the service mark”. Moreover, the intentional confusion caused by the domain meant that the Respondent could not claim that he had made legitimate non-commercial use of the domain name.

The panel then considered whether use of the domain was in bad faith, and as the respondent was using the domain name “for purposes of constitutionally protected political speech”, the panel only considered the categories of bad faith expressly enumerated in the UDRP.

These are (a) registering a domain primarily to sell it on, (b) registering the domain as part of a pattern of registrations to prevent the owner of a trade mark from registering it, (c) using the site to get commercial gain from a likelihood of confusion with the complainant’s mark; or (d) using the domain to disrupt the business of a competitor.

The panel held that none of these applied, as (a) the respondent did not want to sell it on, (b) the registration was not part of a pattern, (c) the respondent was not getting any commercial gain and (d) “only by the exercise of mental gymnastics may a group of gay rights activists be defined as a “competitor” of a conservative public policy think tank”.

Accordingly, the panel declined to make a finding of bad faith, and the domain name was not transferred.

Conclusion

When seeking to parody, be careful to only use the ideas behind the original work, avoid copying direct text, and make it clear that the parody is a parody. If you want to parody a trade mark, be careful either to come within the exemptions in the Comparative Advertising Directive, or that you are not riding on the coat tails of the parodied mark.

When looking to guard against parodies, the most important point is to effectively monitor use of your brand so that you are able to respond to before a work becomes widespread. If your work or brand is parodied, look at whether the parody is doing you any harm, or whether it is just increasing your own recognition. And if you do decide to act – act quickly.

This article was first published in Intellectual Property Magazine

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