Case Nos: IL-2023-000080 and IL-2024-000038 - [2025] EWHC 2561 (Ch)
Chancery Division of the High Court

Case Nos: IL-2023-000080 and IL-2024-000038 - [2025] EWHC 2561 (Ch)

Fecha: 10-Oct-2025

Database right

Database right

Subsistence and ownership of database right

201.

Mr Blanchard gave evidence about how he created the GBR Database, beginning with the PAF for which he purchased a licence from RMG in early 2013. Mr Blanchard worked on the raw data to make a usable and searchable database, writing his own specialist software to assist in this. He offered Ideal Postcodes to his first customer in August 2013.

202.

Over the next 10 years or so Mr Blanchard integrated further address data from sources other than the PAF. The GBR Database was also updated on a daily basis, with work done on modifying the data to correct for errors and to provide for more efficient searching and retrieval. By the end of 2024 Mr Blanchard had enlisted two software developers to assist in the work. None of this was challenged in cross-examination.

203.

I find that at all material times since immediately before Mr Smith’s first access to the GBR Database there was a substantial investment in obtaining, verifying and presenting the contents of the PAF and then the GBR Database as developed from the PAF. Database right has throughout that period subsisted in the GBR Database.

204.

The individual who carried out the investment concerned was Mr Blanchard. In its Particulars of Claim IDDQD pleaded reliance on confirmatory deeds of assignment by which the database right in the GBR Database was assigned to IDDQD. The defendants did not admit ownership but no point was taken at the trial. I find that the database right is owned by IDDQD.