Was argued that as Claimant had been commissioned to create databases, copyright in these was vested in Defendant.
If Claimant is commissioned to carry out work for Defendant, in absence of express or implied agreement to contrary work belongs to Claimant.
Mere fact that Claimant has been commissioned does not mean commissioner is entitled to the copyright
However implied agreement to contrary may be found if it is reasonably necessary to give business efficacy to contract.