Hasbro Consumer Products Licensing Limited & Anor v Công ty TNHH Đầu tu Công nghe và Dich vu Sconnect Viet Nam & Ors

Where a copyright claim is pleaded by reference to a representative sample, the court may draw inferences about a wider corpus if the sample is genuinely random and representative, the evidence is compelling, and testing every item would be disproportionate. A defendant’s generalised pleading that does not engage with the sampling case may also amount to an admission under Civil Procedure Rules 1998 Part 16.5(5). Relief may therefore extend beyond individually matched items, including takedown and future-use injunctions, subject to proportionate limits. A publicity order is proper where its terms are factual and informative. An appeal does not automatically stay enforcement under Part 52.16.

The claimants, Hasbro Consumer Products Licensing Limited and Astley Baker Davies Limited, obtained summary judgment on a sound-recording copyright claim concerning Peppa Pig audio clips copied into Wolfoo animation videos. The earlier judgment was reported at [2026] EWHC 1546 (Ch).

This judgment determined consequential relief. The central issues were whether representative-sample evidence justified relief extending to the wider Wolfoo corpus, the scope of declarations, injunctions, delivery up and publicity, the appropriate costs order, and the defendants’ applications for permission to appeal and a stay of execution.

The court granted broad consequential relief following the claimants’ successful summary judgment application.

1. Representative sampling. The defendants had been given fair notice that the tested videos were representative of a larger corpus but had not meaningfully engaged with that case. Their related allegations were therefore treated as admitted under Civil Procedure Rules 1998 Part 16.5(5). Independently, the evidence established that the samples were randomly selected and genuinely representative. The high match rates, the number of matches and the disproportionate cost of analysing more than 30,000 videos justified safe inferences extending beyond the individually tested videos. The defendants had no real prospect of resisting those inferences.
2. Declarations and injunctions. Declaratory relief properly covered videos containing listed Peppa Pig sounds and other sounds copied from Peppa Pig soundtracks. Given the prolific and continuing infringement, the injunction could extend to all in-scope Wolfoo videos online at the date of the order and prohibit future creation, uploading, communication, re-uploading, procuring and authorising of infringing material.
3. Proportionality and scope. The order was limited to the first and fourth defendants and did not impose responsibility for channels outside their control. The defendants were required to identify controlled online outlets and update that information monthly. The territorial scope could refer to countries becoming parties to the relevant conventions from time to time because the injunction imposed continuing obligations.
4. Ancillary relief. Delivery up could include publicly available Peppa Pig videos downloaded without licence, even though copying into Wolfoo videos had not been separately established. Any inquiry into loss or account would remain limited to the infringements found, with apportionment arguments available.
5. Publicity. Applying the approach in Samsung Electronics (UK) Ltd v Apple Inc [2012] EWCA Civ 1339, publication was appropriate because the proposed notice was measured, factual and informative rather than punitive.
6. Costs and appellate applications. The claimants were successful overall and were entitled to their costs, subject to detailed assessment and payments on account. Permission to appeal was refused because none of the five grounds had a real prospect of success or disclosed a compelling reason. Under Part 52.16, an appeal would not automatically stay enforcement. The defendants showed no sufficient prejudice to outweigh the evidenced harm from continuing infringement, so the stay was refused.

This was a first-instance consequential judgment, not an appeal.

1. High Court (Intellectual Property List): The claimants obtained summary judgment on the sound-recording copyright claim in the earlier judgment, reported at [2026] EWHC 1546 (Ch) .
2. High Court (Intellectual Property List): The present court determined consequential relief, costs, permission to appeal and stay of execution. Permission to appeal was refused, with any renewal to the Court of Appeal to be made within 21 days.