What was the dispute about?
This case arose between two competing property-technology businesses, Edozo and Valos, both of which offer software that generates property valuation reports and related information for customers.
Valos alleged that Edozo had copied important aspects of its platform when developing its own reporting product. In particular, Valos claimed that Edozo's system followed a very similar sequence of user interactions and report-generation steps. Valos argued that, even if Edozo had not copied Valos's source code directly, it had indirectly copied the underlying computer programs by reproducing how the software operated from a user's perspective.
Edozo applied to strike out this part of Valos's claim before trial, arguing that the allegation was not legally sustainable.
The key legal issue
The central question was:
If one software developer creates a new program that behaves in a similar way to a competitor's program, but does not copy that competitor's source code, can that amount to copyright infringement?
Valos argued that the answer should be yes. It said that Edozo had copied the "dynamic logic and modularity" of its platform, meaning the sequence of steps and interactions users experienced when generating reports.
Edozo argued that copyright in software protects the source code itself (and its expression), not the software's functionality or the business process it performs.
What did the court decide?
Judge Hacon agreed with Edozo.
The court held that:
Copyright protects the expression of a computer program, such as its source code.
Copyright does not protect the functionality of a program, meaning what the program does or the sequence of operations it performs.
Even if Edozo had copied the user-facing workflow or functionality of the Valos platform, that would not amount to infringement of copyright in Valos's source code.
The judge relied heavily on earlier authorities including Navitaire v easyJet, Nova Productions v Mazooma Games and SAS Institute v World Programming, all of which emphasise that copyright does not give a monopoly over software functionality or business logic.
The judge's reasoning in simple terms
The court used an analogy that has appeared in previous software copyright cases.
If a chef invents a new pudding and writes down a recipe, another chef is free to taste the pudding and work out for themselves how to make a similar one. The second chef may end up with a different recipe that produces a similar result. Copyright protects the first chef's written recipe, but not the pudding itself.
Similarly, the court said that software copyright protects the written code, not the functionality or outcome achieved by that code.
Outcome
The court struck out the parts of Valos's Defence and Counterclaim that alleged indirect infringement of copyright in the Valos computer programs and coded prompts. Those allegations could not succeed as a matter of law because they were based on alleged copying of software functionality rather than copying of the protected source code or another copyright-protected expression.
Importantly, the decision did not determine whether Edozo had copied Valos's report templates, graphical interfaces or other materials. Those aspects of Valos's copyright claims were not the subject of this application.
Why the case matters
This judgment reinforces a long-established principle in UK software law:
Copyright does not prevent competitors from creating software that performs the same functions or follows similar workflows, provided they do not copy the protected code or other copyright-protected expression.
For software developers, the case is a reminder that copyright protection has limits. If a company wishes to protect genuinely innovative functionality, it may need to rely on patents, confidentiality, contractual protections, or copyright in specific user interfaces and documents, rather than copyright in software source code alone.
Read the judgment here: https://caselaw.nationalarchives.gov.uk/ewhc/ipec/2026/93)
