Where the postcodes are—High Court finds database right infringement (IDDQD and Royal Mail v Codeberry)
IP analysis: A judgment of the High Court, Chancery Division addressed the complex intersection of database right and copyright in digital address data. The case brought by IDDQD Ltd, creator of the ‘Ideal Postcodes’ service, and Royal Mail Group Ltd (RMG), owner of the Postcode Address File (PAF), and centred on the unauthorised use of substantial parts of the PAF and IDDQD’s ‘GBR Database’ in a competing address search service ‘GetAddress’. The court found that the defendants had extracted and re-utilised significant portions of both claimants’ databases without licence, infringing database right and copyright. The judgment clarifies the boundaries between lawful ‘consultation’ of a database and unlawful ‘extraction’ or ‘re-utilisation’, reaffirms the strict limits of implied consent in data use, and highlights the exposure of technology start-ups that build upon licensed datasets without appropriate authorisation.