Case Brief

The Plaintiff Shu X (Beijing) Technology Co., Ltd. (hereinafter referred to as "Shu X"), having lawfully obtained authorization, collected a Mandarin Chinese speech dataset totaling 1,505 hours involved in the case and registered it with a Data Intellectual Property Registration Certificate. Shu X claimed that the Defendant Yin X (Shanghai) Technology Co., Ltd. (hereinafter referred to as "Yin X") publicly released a 200-hour subset of Shu X's dataset (hereinafter referred to as the "involved dataset") without permission, constituting unfair competition.

The court of first instance ruled that the dataset involved in the case constituted a trade secret, and Yin X's disclosure and use of it infringed Shu X's trade secret, ordering compensation of RMB 102,300. Yin X appealed against the judgment.

The court of second instance held that the Data Intellectual Property Registration Certificate serves as preliminary evidence of Shu X's lawful ownership and legitimate acquisition of the dataset. Although the involved dataset failed to meet the criteria for a trade secret due to its disclosure and also failed to meet the criteria for a compilation, it comprised commercially valuable data entries formed through significant investment in technology, capital, and labor by Shu X, and its legitimate interests are protected by the Anti-Unfair Competition Law. Data users must comply with the terms of open-source licenses when using open-source data. Yin X failed to comply with the relevant license, thereby violating commercial ethics, harming Shu X's interests and competitive market order, and violating Article 2 of the Anti-Unfair Competition Law. Accordingly, the court of second instance adjusted the finding on trade secrets but upheld the ruling of the court of first instance.

Typical Significance

This case is the first to affirm the preliminary evidentiary effect of Data Intellectual Property Registration Certificates on rights ownership and acquisition legitimacy and to actively address theoretical and practical concerns by reasonably and accurately defining the rights and obligations of all participants in the data ecosystem. The final judgment aligns with national policy objectives to promote data circulation and utilization while maintaining fair competition in the data services sector.

(Source: Beijing Court 2024 Top 10 IP Judicial Protection Cases)