1. Introduction

Copyright infringement civil claims in Singapore concern the unauthorised use, reproduction, distribution, communication, adaptation or commercial exploitation of copyright-protected works.

Copyright is an important component of intellectual property law because it protects the creative and economic interests of authors, artists, software developers, musicians, filmmakers, publishers, photographers and other rights holders.

In Singapore, copyright infringement disputes frequently arise in connection with:

Literary and academic publications.

Books, articles and educational materials.

Computer software and source code.

Music compositions and sound recordings.

Films and audiovisual productions.

Photographs and digital artwork.

Websites and online publications.

Artificial intelligence-generated and AI-assisted content.

Digital databases and commercial content platforms.

Social media and online content distribution.

The principal legislation is the Copyright Act 2021, which modernised Singapore's copyright framework and replaced the Copyright Act (Cap. 63).

Copyright infringement may result in civil proceedings seeking injunctions, damages, an account of profits, delivery up of infringing materials and other appropriate remedies.

An important distinction is that copyright protects the expression of ideas rather than the underlying ideas, facts, methods or concepts themselves.

2. Legal framework governing copyright infringement in Singapore

A. Copyright Act 2021

The Copyright Act 2021 is the central legislation governing copyright protection and enforcement in Singapore.

It establishes rules concerning:

Ownership of copyright.

Originality requirements.

Copyright duration.

Exclusive rights of copyright owners.

Permitted uses and statutory exceptions.

Primary and secondary infringement.

Civil remedies.

Technological protection measures.

Rights-management information.

Enforcement against unauthorised exploitation.

The Act protects different categories of copyright works, including literary, dramatic, musical and artistic works, as well as films, sound recordings and broadcasts.

B. Exclusive rights of copyright owners

Copyright owners generally enjoy exclusive rights to control specified uses of their protected works.

These include:

Reproduction of the work.

Publication and distribution.

Communication to the public.

Performance in public.

Adaptation, where applicable.

Commercial exploitation through licensing arrangements.

For example, a publisher cannot ordinarily reproduce and commercially distribute another author's protected book without authorisation.

Similarly, uploading a copyrighted film to an online platform without permission may constitute infringement.

C. Originality requirement

Copyright protection generally requires originality.

Originality does not mean that a work must be completely new or revolutionary.

Instead, the work must satisfy the applicable statutory requirements concerning independent creation and sufficient intellectual contribution.

Examples include:

An independently written research article.

An original photograph.

A computer program.

An original musical composition.

An independently created illustration.

Copyright does not automatically protect every piece of information appearing in a document. Facts, ideas and general information must be distinguished from their original expression.

D. Copyright ownership

Ownership is particularly important in civil litigation.

The author is generally the first owner, subject to statutory exceptions and applicable contractual arrangements.

Ownership disputes may arise involving:

Employees creating works during employment.

Freelance designers.

Software developers.

Commissioned photographers.

Publishing agreements.

Film-production arrangements.

Joint authorship.

Assignment and licensing agreements.

A claimant must establish an appropriate legal interest in the copyright before obtaining remedies as a copyright owner.

E. Copyright infringement

Copyright infringement may occur when a person performs an act restricted by copyright without the required authorisation.

The claimant generally needs to establish:

The existence of a copyright-protected work.

The claimant's ownership or relevant enforcement rights.

An act falling within the exclusive rights of copyright.

A causal connection between the defendant's conduct and the infringement.

The question of whether a substantial part of a work has been copied is particularly important.

Substantiality is assessed qualitatively, not simply by measuring the number of words, pages or seconds copied.

3. Important Singapore case laws on copyright infringement

The following decisions are particularly useful for understanding copyright ownership, originality, substantial copying, digital infringement, authorisation liability and remedies.

Case 1. Global Yellow Pages Ltd v Promedia Directories Pte Ltd [2017] SGCA 28

Singapore Court of Appeal

Facts:

Global Yellow Pages operated telephone directories containing business listings and classified information. It alleged that Promedia, a competing directory publisher, had copied information from its printed and online directories.

The dispute concerned whether copyright subsisted in the individual listings, enhanced data, compilations and directory arrangements.

Judgment:

The Court of Appeal dismissed the copyright infringement appeal.

The court explained that copyright protection depends on the existence of an original intellectual creation. Investment, effort and commercial value alone do not automatically create copyright protection.

The court distinguished between unprotected information and original expression resulting from intellectual creation.

Legal principles:

Copyright does not protect facts merely because substantial resources were invested in collecting them.

Originality is essential for copyright protection.

A compilation may qualify for copyright where its selection or arrangement involves sufficient intellectual creation.

The claimant must identify the particular protected work and establish infringement of that work.

Significance in Singapore:

This is a leading Singapore authority on copyright protection for databases, directories and compilations.

It is particularly important for disputes involving digital databases, commercial information platforms and AI training datasets.

Case 2. Asia Pacific Publishing Pte Ltd v Pioneers & Leaders (Publishers) Pte Ltd [2011] SGCA 37

Singapore Court of Appeal

Facts:

The dispute concerned competing publishers and copyright protection in published material, including the preparation and use of publications.

The central question involved the originality requirements for copyright protection.

Judgment:

The Court of Appeal considered the relationship between independent intellectual effort, originality and the subsistence of copyright.

The decision is important for understanding that copyright protects original expression rather than the mere expenditure of labour or commercial resources.

Legal principles:

Copyright requires originality.

The relevant intellectual contribution must be attributable to the author.

The nature of the work and the manner in which it was created matter.

The claimant must establish that the material alleged to have been copied qualifies for copyright protection.

Significance:

The case is useful in disputes involving publishers, educational institutions, research organisations and commercial content creators.

Case 3. RecordTV Pte Ltd v MediaCorp TV Singapore Pte Ltd and others [2010] SGCA 43

Singapore Court of Appeal

Facts:

RecordTV operated an internet-based digital video recording service.

Its users could request recordings of free-to-air television programmes and watch them later through the online service.

MediaCorp alleged infringement of its copyright in television broadcasts and programmes.

Judgment:

The Court of Appeal allowed RecordTV's appeal.

It concluded that the users, rather than RecordTV, made the relevant recordings. The service did not itself communicate the programmes to the public in the circumstances, nor did it authorise infringement.

The court considered the relationship between copyright protection, technological development and the legitimate use of digital recording facilities.

Legal principles:

The person who makes a copy must be identified.

Communication to the public requires examination of the actual nature of the communication.

Providing technological facilities does not automatically amount to authorising copyright infringement.

Copyright law must be applied in a manner that takes account of technological developments and legitimate public interests.

Significance:

This case is particularly relevant to online streaming, cloud recording, digital platforms, user-generated content and technology service providers.

Case 4. Ong Seow Pheng and others v Lotus Development Corp and another [1997] 2 SLR(R) 113

Singapore Court of Appeal

Facts:

The dispute involved the unauthorised distribution of computer software and accompanying manuals.

The copyright owners alleged that the defendants had dealt in infringing software copies and were responsible for copyright infringement.

Judgment:

The Court of Appeal examined the meaning of authorisation under copyright law.

It explained that authorisation involves granting or purporting to grant another person the right to perform an act comprised in copyright.

Merely facilitating or encouraging another person's conduct does not necessarily amount to authorisation.

Legal principles:

Authorisation liability requires more than passive assistance.

The defendant must have granted or purported to grant the relevant authority.

The defendant's control over the infringing activity is relevant.

Commercial involvement in distributing infringing copies may expose a defendant to liability.

Significance:

This case is especially important for software piracy, digital distribution, online marketplaces and businesses involved in the supply of unauthorised copyrighted materials.

Case 5. New Line Productions, Inc and another v Aglow Video Pte Ltd and others [2005] 3 SLR(R) 660

Singapore High Court

Facts:

The dispute involved the unauthorised commercial distribution of copyrighted films in video compact disc format.

The copyright owners brought proceedings against businesses involved in dealing with infringing copies.

Judgment:

The High Court considered copyright infringement and the appropriate remedies, including additional damages.

The court took account of the commercial scale of infringement and the need to deter deliberate or commercially motivated copyright violations.

Legal principles:

Commercial distribution of unauthorised film copies can constitute copyright infringement.

Copyright owners may pursue monetary remedies.

Additional damages may be appropriate in circumstances involving deliberate or aggravated infringement.

The scale and nature of the infringement are relevant to the assessment of remedies.

Significance:

The case is useful for film piracy, unauthorised entertainment distribution, counterfeit digital media and commercial copyright enforcement.

Case 6. Siemens Industry Software Inc v Inzign Pte Ltd [2023] SGHC 50

Singapore High Court

Facts:

An employee of Inzign Pte Ltd installed an unauthorised version of Siemens commercial software on a workplace laptop.

The employee used modules of the software for several months before the conduct was discovered.

Siemens commenced proceedings alleging copyright infringement and seeking damages.

Judgment:

The High Court found copyright infringement arising from the employee's unauthorised use of the software.

However, the court examined separately whether the employer was legally responsible for the employee's conduct.

It considered the principles governing primary infringement and vicarious liability.

Legal principles:

Unauthorised installation and use of copyrighted software may constitute infringement.

An employer is not automatically liable merely because an employee committed an infringement at work.

The defendant's control over the infringing activity is relevant.

The distinction between primary infringement and secondary or vicarious responsibility must be maintained.

Damages must be assessed by reference to the applicable legal principles.

Significance:

This decision is particularly important for software licensing, workplace compliance, corporate IT management and unauthorised commercial software installation.

It demonstrates that companies should maintain effective software-licensing and access-control systems.

Case 7. Fujifilm Business Innovation Asia Pacific Pte Ltd v PTC Business Systems Pte Ltd [2022] SGHC 100

Singapore High Court

Facts and legal issues:

The dispute involved copyright infringement allegations relating to software and firmware, together with issues concerning rights-management information.

The proceedings examined unauthorised dealings with protected software and the remedies available to copyright owners.

Judgment and principles:

The High Court considered the appropriate approach to monetary relief, including additional damages.

The court discussed the deterrent and punitive purposes of additional damages and the importance of avoiding an unjustified windfall for a claimant.

Significance:

This case is useful for:

Software copyright infringement.

Firmware protection.

Corporate licensing disputes.

Rights-management information.

Additional damages.

Commercial enforcement of intellectual property rights.

Case 8. Federal Computer Services Sdn Bhd v Ang Jee Hai Eric [1993] SGHC 92

Singapore High Court

Facts:

The proceedings concerned alleged infringement of copyright in computer software, alongside allegations involving misuse of confidential information and breaches of fiduciary duties by a former employee.

The plaintiffs sought injunctive relief and damages.

Legal significance:

The decision addressed copyright ownership and the evidential issues involved in software-related intellectual property litigation.

It illustrates the importance of establishing:

Ownership of the software copyright.

The relevant contractual and employment arrangements.

The nature of the software materials.

The defendant's alleged unauthorised conduct.

The distinction between copyright infringement and misuse of confidential information.

Application:

This case is relevant to disputes involving software developers, former employees, technology companies and competing businesses.

It is an older decision under the previous copyright legislation, so its principles must be applied consistently with the current Copyright Act 2021.

4. Essential elements of a civil copyright infringement claim

A claimant commencing civil proceedings in Singapore must establish the legal basis of the claim.

A. Subsistence of copyright

The claimant must prove that copyright exists in the relevant work.

Examples include:

An original book.

A photograph.

A computer program.

A musical composition.

A film.

An artistic illustration.

The court examines whether the material falls within a protected category and satisfies the relevant statutory requirements.

B. Ownership of copyright

The claimant must establish that they own the copyright or possess the relevant legal rights to enforce it.

Useful evidence includes:

Original manuscripts.

Employment agreements.

Copyright assignments.

Publishing contracts.

Software development agreements.

Licensing documents.

Creation records.

A person who merely possesses a copy of a copyrighted work does not automatically own its copyright.

C. Copying of protected material

The claimant must establish that the defendant copied protected material.

Copying may occur through:

Direct reproduction.

Scanning and duplication.

Digital downloading.

Source-code copying.

Reproduction of photographs.

Unauthorised recording.

Uploading copyrighted material.

Evidence of access to the original work may be relevant, but access alone does not establish infringement.

D. Substantial part infringement

Copying does not need to involve an entire work.

Reproduction of a substantial part may constitute infringement.

The court examines the quality and importance of the material taken rather than relying exclusively on its quantity.

For example, copying a distinctive and important portion of a software program may constitute infringement even if the entire program has not been reproduced.

E. Absence of authorisation

The claimant must establish that the relevant restricted act was not authorised by the copyright owner or otherwise permitted by law.

A defendant may rely on:

An express licence.

An implied licence.

A statutory exception.

Fair dealing.

Other applicable permitted uses.

5. Major categories of copyright infringement civil claims

A. Literary copyright infringement

Literary infringement involves unauthorised reproduction or exploitation of protected written material.

Examples:

Copying books.

Reproducing research papers.

Republishing articles.

Copying educational materials.

Reproducing protected website content.

B. Software copyright infringement

Software disputes frequently involve:

Unlicensed installation.

Unauthorised software duplication.

Source-code copying.

Commercial distribution of pirated software.

Breach of software licensing arrangements.

The Siemens decision provides a particularly useful Singapore example.

C. Music copyright infringement

Music copyright disputes may involve different protected interests, including copyright in musical compositions and sound recordings.

Examples include:

Unauthorised commercial music distribution.

Reproduction of musical compositions.

Unlicensed recordings.

Unauthorised online streaming.

Commercial exploitation of protected musical content.

The rights of composers, performers, producers and recording owners must be examined separately.

D. Film and television copyright infringement

Film-related infringement may involve:

Pirated film distribution.

Unauthorised online streaming.

Illegal recording.

Reproduction of protected audiovisual content.

Unauthorised commercial exhibition.

RecordTV and New Line Productions provide important judicial guidance in this area.

E. Photography and artistic copyright infringement

Photographers and artists may pursue claims involving:

Unauthorised commercial reproduction.

Copying photographs for advertising.

Reproduction of illustrations.

Unauthorised use of digital artwork.

Commercial exploitation of protected images.

F. Digital platform infringement

Digital platforms may face claims involving the hosting, reproduction or communication of protected material.

However, liability depends on the platform's conduct and the applicable statutory provisions. Merely providing technological infrastructure does not automatically establish infringement.

6. Civil remedies available under Singapore copyright law

Part 6 of the Copyright Act 2021 provides the framework for civil remedies against rights infringements.

Under section 305, the court may grant several forms of relief.

A. Injunctions

An injunction is a court order restraining a defendant from continuing or repeating infringing activities.

Examples include:

Stopping the distribution of pirated books.

Preventing unauthorised software reproduction.

Restricting illegal film distribution.

Preventing further commercial use of copyrighted photographs.

Stopping unauthorised online publication.

An interim injunction may also be sought where the legal requirements for urgent interim relief are satisfied.

B. Compensatory damages

Damages compensate the copyright owner for the loss caused by infringement.

Potential losses include:

Lost licensing revenue.

Lost sales.

Loss of commercial opportunities.

Unauthorised exploitation of intellectual property.

Other legally recoverable financial losses.

The claimant must establish the relevant loss and its connection with the infringement.

C. Additional damages

The court may award additional damages where the statutory requirements are satisfied.

Relevant considerations include:

The flagrancy of infringement.

The benefit obtained by the defendant.

The need for deterrence.

The circumstances of the infringement.

The objective is to address particularly serious infringement rather than simply compensate for ordinary financial loss.

D. Account of profits

Instead of ordinary compensatory damages, the claimant may seek an account of profits attributable to the infringement.

For example, where a business earns substantial revenue by commercially distributing pirated films, the copyright owner may seek an account of the profits attributable to that infringement.

The claimant must elect between the principal alternative monetary remedies, subject to the statutory provisions concerning overlapping recovery.

E. Statutory damages

Statutory damages provide an alternative where proving the precise amount of actual financial loss may be difficult.

The court considers the statutory factors, including:

The nature and purpose of the infringement.

Whether the conduct was commercial.

The flagrancy of the infringement.

The need for deterrence.

The defendant's benefit.

The proportionality of the award.

F. Delivery up and disposal orders

The court may order the surrender or disposal of infringing articles.

Examples include:

Pirated DVDs.

Unauthorised printed books.

Counterfeit publications.

Infringing storage media.

Other materials used in unlawful reproduction.

These remedies are particularly important where continued possession or distribution would facilitate further infringement.

7. Defences available in copyright infringement proceedings

A defendant may contest a civil copyright claim using several statutory and legal defences.

A. Fair dealing

Fair dealing is an important statutory exception.

Depending on the circumstances, permitted purposes include:

Research.

Private study.

Criticism or review.

Reporting current events.

Other specifically recognised statutory purposes.

The relevant statutory conditions must be satisfied.

For example, using limited copyrighted material for genuine criticism or review may be permissible, depending on the circumstances and applicable acknowledgement requirements.

B. Independent creation

A defendant may establish that the allegedly similar work was independently created.

Copyright infringement generally requires copying of protected expression.

Similarity alone does not automatically establish infringement.

C. Absence of originality

A defendant may argue that the claimant's material does not satisfy the requirements for copyright protection.

This defence is particularly relevant to:

Raw facts.

General information.

Ideas.

Common expressions.

Non-original compilations.

The Global Yellow Pages decision is especially relevant.

D. Licence and authorisation

A valid copyright licence may permit acts that would otherwise infringe copyright.

Disputes may arise concerning:

Licence duration.

Territorial scope.

Permitted users.

Commercial exploitation.

Sub-licensing.

Contractual restrictions.

E. Statutory permitted uses

The Copyright Act contains exceptions permitting specified uses in particular circumstances.

These include certain educational, library, archival, accessibility and other recognised uses.

The precise statutory conditions must be examined rather than assuming that every educational or non-commercial use is automatically lawful.

F. No substantial part copied

A defendant may argue that the material taken does not amount to a substantial part of the protected work.

The court examines the quality and significance of the copied material.

G. No authorisation liability

A defendant who provides technology or services may argue that it did not authorise the infringing act.

The RecordTV and Ong Seow Pheng decisions are particularly relevant to this defence.

8. Copyright infringement in the digital economy

Singapore's copyright framework has considerable importance in the digital economy.

A. Online piracy

Online piracy includes the unauthorised distribution of copyrighted books, films, music and software.

Civil claims may be brought against persons responsible for infringing activities, subject to the applicable legal requirements.

B. Social media infringement

Social media users and commercial accounts may infringe copyright by uploading or reproducing protected content without permission.

Examples include:

Reposting photographs commercially.

Uploading copyrighted films.

Republishing articles.

Using protected music in commercial advertisements.

Copying illustrations for product promotion.

C. Artificial intelligence and copyright

AI creates new copyright-related disputes involving:

Use of copyrighted material in training datasets.

Reproduction of protected content.

AI-generated outputs resembling existing works.

Unauthorised commercial exploitation.

Ownership of AI-assisted creative works.

A critical distinction is that the use of copyrighted material for AI training does not automatically establish infringement in every case, nor is it automatically exempt.

The relevant questions include the nature of the material used, the acts undertaken, applicable statutory exceptions and the circumstances of the particular use.

The claimant must also establish copyright in the relevant work and an infringing act.

D. Corporate copyright compliance

Businesses should adopt effective copyright-management procedures.

Recommended measures include:

Maintaining software licence records.

Obtaining written content permissions.

Recording copyright assignments.

Monitoring digital content use.

Training employees.

Reviewing third-party supplier agreements.

Establishing procedures for responding to infringement complaints.

The Siemens decision illustrates why workplace software compliance is important.

9. Civil litigation procedure in Singapore

Copyright infringement claims generally proceed through the appropriate Singapore court under the applicable civil procedure rules.

Stage 1: Identification of infringement

The claimant identifies the protected work and the allegedly infringing conduct.

Stage 2: Establishment of ownership

The claimant collects evidence of copyright ownership or enforcement rights.

Stage 3: Evidence collection

Evidence may include:

Original creative files.

Publication records.

Source code.

Copyright registrations where relevant.

Licensing agreements.

Website screenshots.

Digital access records.

Sales and distribution records.

Stage 4: Legal notice

The claimant may send a cease-and-desist letter identifying the infringement and requesting that the conduct stop.

Stage 5: Commencement of proceedings

Where the dispute cannot be resolved, the claimant may commence civil proceedings seeking appropriate remedies.

Stage 6: Interim relief

Where necessary, the claimant may seek urgent injunctions or other interim orders.

Stage 7: Trial and determination

The court considers copyright ownership, originality, infringement, defences, causation and remedies.

Stage 8: Enforcement

The successful claimant may enforce the court's orders in accordance with applicable procedural requirements.

Evidence and digital forensics

Digital evidence is particularly important in modern copyright litigation.

Relevant materials may include:

Server logs.

Download records.

Source-code comparisons.

Metadata.

File modification histories.

Emails.

Messaging records.

Cloud-storage records.

Website archives.

Commercial sales data.

Proper preservation and authentication of digital evidence can significantly influence the outcome of proceedings.

10. Relationship between copyright infringement and other civil claims

Copyright infringement may overlap with other causes of action.

The decision in I-Admin (Singapore) Pte Ltd v Hong Ying Ting and others [2020] SGCA 32 is relevant to the relationship between copyright and breach of confidence.

The Court of Appeal developed an approach to breach of confidence involving confidential information and unauthorised use. However, breach of confidence and copyright infringement remain distinct causes of action, with different legal requirements.

11. Critical challenges in Singapore copyright litigation

A. Difficulty proving ownership

Digital content is frequently created collaboratively. Determining the original author and legal owner can therefore become complicated.

B. International copyright infringement

Online content can be copied and distributed across multiple jurisdictions.

Singapore courts may need to consider territorial jurisdiction, applicable law and the relevant international copyright framework.

C. Digital evidence

Infringers may delete files, modify metadata or use anonymous accounts.

This creates difficulties in establishing the identity of the infringer and proving the extent of unauthorised reproduction.

D. Balancing copyright and public interest

Copyright protection must coexist with legitimate activities such as education, research, criticism, innovation and technological development.

The RecordTV decision demonstrates the importance of examining the actual conduct instead of automatically treating technological assistance as infringement.

E. Artificial intelligence

AI-generated content creates difficult questions concerning authorship, originality, training materials and unauthorised reproduction.

Singapore's existing copyright framework provides relevant principles, but specific disputes involving emerging AI technologies may require further judicial clarification.

12. Recommendations for strengthening copyright enforcement in Singapore

The following measures could improve copyright protection:

Digital copyright monitoring: Improve systems for identifying unauthorised online reproduction.

Software compliance: Strengthen corporate software licensing and auditing.

Creator protection: Improve contractual safeguards for independent authors, artists and photographers.

AI transparency: Develop clearer practices for documenting the provenance and lawful use of training materials.

Efficient dispute resolution: Encourage mediation and appropriate alternative dispute resolution.

Evidence preservation: Improve digital forensic capabilities and preservation procedures.

International cooperation: Strengthen cross-border enforcement against commercial digital piracy.

13. Overall assessment of the eight principal cases

These decisions should be read alongside the Copyright Act 2021. The older cases arose under previous copyright legislation, although their relevant common-law principles remain important subject to the current statutory framework.

14. Conclusion

Civil law claims involving copyright infringement in Singapore provide important protection for creative works, commercial publications, computer programs, music, films, photographs and digital content.

The Copyright Act 2021 establishes the modern statutory framework for copyright ownership, infringement, permitted uses and civil remedies.

The Singapore courts have developed significant principles through decisions such as Global Yellow Pages v Promedia, RecordTV v MediaCorp, Ong Seow Pheng v Lotus Development, New Line Productions v Aglow Video and Siemens Industry Software v Inzign.

Three fundamental principles emerge:

Copyright protection requires a legally protected work and appropriate originality.

Infringement requires an unauthorised act involving rights protected by copyright.

Civil remedies must be supported by the applicable statutory requirements and evidence.

Ultimately, Singapore's copyright framework seeks to balance the legitimate economic interests of creators and copyright owners with public access to information, technological innovation, education and freedom of lawful expression.

The central legal position is that unauthorised commercial exploitation of protected creative expression can give rise to civil liability, provided that copyright subsistence, ownership and infringement are established and no applicable defence succeeds.

Principal statutory and judicial references

Copyright Act 2021.

Copyright (Border Enforcement Measures) Regulations, where applicable.

Rules of Court 2021.

Global Yellow Pages Ltd v Promedia Directories Pte Ltd [2017] SGCA 28.

Asia Pacific Publishing Pte Ltd v Pioneers & Leaders (Publishers) Pte Ltd [2011] SGCA 37.

RecordTV Pte Ltd v MediaCorp TV Singapore Pte Ltd [2010] SGCA 43.

Ong Seow Pheng v Lotus Development Corp [1997] 2 SLR(R) 113.

New Line Productions Inc v Aglow Video Pte Ltd [2005] 3 SLR(R) 660.

Siemens Industry Software Inc v Inzign Pte Ltd [2023] SGHC 50.

Fujifilm Business Innovation Asia Pacific Pte Ltd v PTC Business Systems Pte Ltd [2022] SGHC 100.

Federal Computer Services Sdn Bhd v Ang Jee Hai Eric [1993] SGHC 92.

I-Admin (Singapore) Pte Ltd v Hong Ying Ting [2020] SGCA 32.

This is an academic legal analysis, not an opinion on the outcome of a particular dispute.