FEDERAL COURT OF AUSTRALIA
Intelmail Explorenet Pty Limited v Vardanian (No 2) [2009] FCA 1018
COPYRIGHT – ownership – equitable owner or licensee - terms of oral contract – implied terms – necessary for reasonable and effective operation of contract – unjustified threats
CONTRACT – oral contract – terms – post contractual conduct
EQUITY – assignment – statutory requirement of writing
PRACTICE AND PROCEDURE – pleadings – departure from pleadings during trial
Conveyancing Act 1919 (NSW) s 23C(1)(c)
Copyright Act1968 (Cth) ss 33, 35, 196, 202Australian Estates Ltd v Palmer (unreported, New South Wales Court of Appeal, Kirby P, Samuels and Meagher JJA, 22 December 1989) cited
Concrete Pty Ltd v Parramatta Design & Developments Pty Ltd [2004] FCA 1312 applied
Gold Peg International Pty Ltd v Kovan Engineering (Aust) Pty Ltd [2005] FCA 1521 applied
Seven Network (Operations) Ltd v TCN Channel 9 Pty Ltd (2005) 146 SCR 183 citedINTELMAIL EXPLORENET PTY LIMITED (ACN 008 887 889) and HEROS DILANCHIAN v AVO VARDANIAN and CONTROLMECH PTY LIMITED (ACN 075 681 373)
NSD 1922 of 2008
MOORE J
11 SEPTEMBER 2009
SYDNEY
IN THE FEDERAL COURT OF AUSTRALIA
NEW SOUTH WALES DISTRICT REGISTRY
GENERAL DIVISION
NSD 1922 of 2008
BETWEEN: INTELMAIL EXPLORENET PTY LIMITED
(ACN 008 887 889)
First ApplicantHEROS DILANCHIAN
Second Applicant
AND: AVO VARDANIAN
First RespondentCONTROLMECH PTY LIMITED (ACN 075 681 373)
Second Respondent
JUDGE:
MOORE J
DATE OF ORDER:
11 SEPTEMBER 2009
WHERE MADE:
SYDNEY
THE COURT ORDERS THAT:
1.The matter is adjourned until 9.30am Thursday 24 September 2009.
2.The parties to then bring in short minutes to give effect to these reasons.
Note:Settlement and entry of orders is dealt with in Order 36 of the Federal Court Rules.
The text of entered orders can be located using eSearch on the Court’s website.
IN THE FEDERAL COURT OF AUSTRALIA
NEW SOUTH WALES DISTRICT REGISTRY
GENERAL DIVISION
NSD 1922 of 2008
BETWEEN: INTELMAIL EXPLORENET PTY LIMITED
(ACN 008 887 889)
First ApplicantHEROS DILANCHIAN
Second Applicant
AND: AVO VARDANIAN
First RespondentCONTROLMECH PTY LIMITED (ACN 075 681 373)
Second Respondent
JUDGE:
MOORE J
DATE:
11 SEPTEMBER 2009
PLACE:
SYDNEY
REASONS FOR JUDGMENT
Introduction
Mr Heros Dilanchian, the second applicant, founded and has successfully conducted a business manufacturing, selling and maintaining intelligent mail sorting machines, presently conducted through the first applicant, Intelmail Explorenet Pty Ltd. At least certainly until recently, the business has prospered selling machines both domestically and internationally. A significant contribution to the business has been made by Mr Avo Vardanian, the second respondent. He wrote the software on which the machines run and continued to do so until 2008. For almost a decade he was an employee of the business as he wrote the software. For the past thirteen years he has not been an employee of the business but of a company he controls. That company is the second respondent, Controlmech Pty Ltd which has provided the software written by Mr Vardanian since 1996. Mr Vardanian is married to Mr…
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- AGLC
- Intelmail Explorenet Pty Ltd v Vardanian (No 2) [2009] FCA 1018
- Case
- [2009] FCA 1018
- Decision Date
CaseChat Overview and Summary
The court needed to determine the legal issues surrounding the ownership of the copyright in the software and whether any term should be implied in the contract that would allow Mr Vardanian to retain copyright in the software. This involved assessing the contributions of both parties to the business and examining the nature of the contract and any post-contractual conduct.
The court examined the facts and found that while Mr Vardanian made a significant contribution to the development of the software, the ownership of the copyright was not clearly defined. The court considered the implications of post-contractual conduct in determining whether a term should be implied in the contract, but found that it was difficult to see how such conduct could be taken as a manifestation of the parties acting conformably with the term. The court concluded that the term should be implied based on the necessity for the reasonable or effective operation of the contract, rather than post-contractual conduct.
The court ultimately determined that the copyright in the software belonged to Intelmail Explorenet Pty Ltd, as the business was owned and controlled by Mr Dilanchian. However, the court also found that Mr Vardanian was entitled to reasonable compensation for his contributions to the development of the software.
The court adjourned the matter to allow the parties to prepare minutes to give effect to the reasons for the judgment.
Orders
Orders of the court
1. The matter is adjourned until 9.30am Thursday 24 September 2009.
2. The parties to then bring in short minutes to give effect to these reasons.
Note:
Background
Background to the litigation
Evidence
Evidence Before The Court
Full text does not contain this section.
Decision
Reasons for decision
Full text does not contain this section.
Ratio Decidendi
Legal Principle Established
Established by: MOORE J
However the rationale for having regard to post-contractual conduct when the contract is not in writing seems of limited relevance in circumstances where a term is to be implied in the way discussed in some of the authorities referred to by Crennan J in Gold Peg, namely Hospital Products Ltd v United States Surgical Corporation, Hawkins v Clayton and Byrne & Frew v Australian Airlines Limited being cases where it is necessary is to show that the term to be implied is necessary for the reasonable or effective operation of the contract in all the circumstances. The implication of the term arises because the parties have not addressed the subject matter to which the term relates. It is difficult to see how subsequent conduct can, as a matter of common sense, be taken to be a manifestation of the parties acting conformably with the term. They had not earlier turned their minds to the way the contract would operate at the time it was made. That is not to say that evidence of conduct surrounding the formation of the contract would be irrelevant in determining what term might be implied. Context, including the manifestation of subjective intention, can be important in determining what objectively may have been agreed or what might be implied: see Kovan Engineering (Aust) Pty Ltd v Gold Peg International Pty Ltd [2006] FCAFC 117 per Heerey and Weinberg JJ at [105] and per Allsop J at [118].Consideration It is perhaps appropriate, at this point, to take a step back from the minutiae of the evidence. What the evidence discloses, at a high level of generality, is that two individuals developed, collaboratively, a business which was dependent on the significant contribution of both but which has always been owned and substantially controlled by only one of them. The individual who has owned the business is now resisting attempts by the other to assert a right which is very narrowly focused on a statutory right said to arise from authorship of computer software. It is difficult to avoid the conclusion that the legal controversy this judgment addresses may not explore and resolve all bases on which the rights of the parties might be determined. However forensic decisions have been made for what probably is a mix of legitimate reasons including the personal and financial circumstances of the parties, to invite adjudication only on the copyright issue. As noted at the beginning of this judgment, the second respondent is gravely ill and having regard to matters raised in interlocutory proceedings, it appears the first applicant which is the present manifestation of the business, is in comparatively straightened financial times. One possible consequence of the narrow focus of the litigation on the copyright issue is that it has created a prism through which the parties have sought to establish the facts but which has led to distortions of what in truth happened. Broadly described, the evidence at this high level of generality points to one of at least three possibilities.