What was the main legal question?

If the football betting coupons were protected by copyright, and if so, whether copying a substantial part of them amounted to infringement.

How did the Court view originality?

Originality lies in the expression, not the idea. For compilations, it depends on skill, judgment, and labour used to create the work.

What is a ‘substantial part’?

It is judged by quality as well as quantity. Copying key selections and structure can be substantial even if not everything is copied.

Did the defendants infringe?

Yes. Their coupons closely resembled the claimant’s; the Court held that a substantial part was copied in quality and quantity.

Law Easy

02 November, 2025

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Ladbroke v William Hill (1964) — Copyright in Betting Coupons & “Substantial Part” | The Law Easy

Ladbroke (Football) Ltd. v. William Hill (Football) Ltd.

Q: What principle does this case teach students?

Compilations can be protected. If your work shows skill and judgment in selection and arrangement, others cannot copy substantial parts.

[1964] 1 W.L.R. 273

House of Lords 1964 [1964] 1 W.L.R. 273 Appellate Committee Copyright • Compilations ~7 min read

originality in compilations substantial part betting coupons copyright

Quick Summary

This case asks a simple question: are football betting coupons protected by copyright, and if yes, how much copying counts as infringement? The House of Lords said that copyright protects the expression of work, not the idea of a coupon. A coupon that shows skill and judgment in selection and arrangement can be a literary work. Copying a substantial part—judged by quality and quantity—amounts to infringement. Here, the defendants’ coupon was so close that it crossed the line.

Issues

Do these betting coupons attract copyright protection, wholly or partly?
If protected, was there copying of a substantial part and can parts be examined separately?

Rules

Copyright protects expression, not ideas. For compilations, originality depends on skill, judgment, and labour.
“Substantial part” is a mixed test: quality matters as much as quantity.
You may look at the work in parts where that helps decide whether a substantial portion has been copied.

Facts (Timeline)

1951: William Hill (Respondents) start sending weekly fixed-odds football coupons with a designed structure and many lists.

1959: Ladbroke (Appellants) launch coupons that closely resemble William Hill’s format and content.

Layout: Claimants had 16 named lists of matches; defendants had 15 lists with almost identical offerings.

Differences: Defendants used new headings and calculated their own odds, but the overall structure and selections were very similar.

Industry practice: Other firms had diverse coupons. Building the claimant’s coupon took considerable skill and work.

Timeline illustration of coupon development and dispute

Arguments

Appellant (Ladbroke)

Ideas and formats are free; coupons are standard in the trade.
Different headings and their own odds show independent work.
No copying of a substantial part in law.

Respondent (William Hill)

Coupon is a literary compilation built with skill, judgment, and labour.
Selection, arrangement, and structure were taken in bulk.
The similarities go beyond coincidence—amounting to substantial copying.

Judgment

The Court held for the Respondents. Copyright does not protect the idea of a betting coupon, but it does protect the expression—the selected matches, the grouping into lists, and the structure formed with skill and judgment. The defendants copied a substantial part of that expression. Therefore, there was infringement.

Originality: In compilations, it is a matter of degree, judged by skill, judgment, and labour.
Substantiality: Quality and quantity both count; key features copied can be enough.

Judgment concept image with scales of justice

Ratio

Copyright protects the expressive choices in a compilation—selection, arrangement, and presentation. Where those choices show skill and judgment, copying a substantial part of them is infringement, even if some details (like headings or odds) differ.

Why It Matters

Clarifies protection for compilations used in business.
Shows that quality can outweigh mere counting of copied lines.
Guides how to compare two works: look at expression, not bare ideas.

Key Takeaways

Ideas are free; expression is protected.
Compilations need skill + judgment + labour to be original.
Substantial part = quality + quantity, judged together.

Mnemonic + 3-Step Hook

Mnemonic: S-A-M-E — Selection, Arrangement, Matters for Expression.

Spot the expressive choices (what, where, how listed).
Assess quality and quantity of what’s taken.
Match similarities to decide if a substantial part is copied.

IRAC Outline

Issue

Do betting coupons attract copyright, and did the defendants copy a substantial part?

Rule

Copyright protects expression. For compilations, originality depends on skill, judgment, labour. Substantiality is qualitative and quantitative.

Application

The defendants’ coupon mirrored the claimant’s structure and selection. Differences in headings and odds did not avoid copying of core expression.

Conclusion

Glossary

Term	Easy Meaning
Compilation	A work made by selecting and arranging material, like a list or table.
Originality	Not novelty; it means the work shows the author’s skill, judgment, and effort.
Substantial Part	An important portion judged by quality as well as quantity.
Expression vs Idea	Law protects the way you express an idea, not the idea itself.

FAQs

The selection and arrangement of matches and lists—the expressive structure, not the idea of a coupon itself.

Not if the core expression is taken. New headings or different odds were not enough here.

By quality and quantity. Important features copied can be substantial even if not much text is taken.

Yes. Looking at significant parts can help decide if the taken portion is substantial.

Compilations are protectable if built with skill and judgment. Copying their structure can infringe.

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