I. SPC Legal Position on Captioning / Subtitle Revenue Disputes

The SPC generally treats captioning/subtitling revenue disputes under copyright + contract + platform liability principles:

1. Captioning/Subtitling as Copyright-Related Derivative Work

• Subtitles/captioning are considered part of the audiovisual work exploitation chain
• Unauthorized captioning or translation = potential adaptation or derivative infringement

2. Revenue Allocation Principle

The SPC focuses on:

• Who owns information network dissemination rights
• Whether captioning is part of licensed exploitation rights
• Whether platform earns revenue (ads/subscription) using subtitled content

3. Platform Liability Doctrine

If subtitles are uploaded by users:

• Platforms may be liable if they fail to control infringing subtitle content
• But safe harbor applies if proper takedown systems exist

4. Contractual Royalty Allocation

Many disputes revolve around:

• Licensing contracts between studios and platforms
• Whether subtitle creation revenue belongs to:
  • content owner
  • platform
  • or subtitle producer

5. Anti-Unfair Competition Angle

Unauthorized use of subtitles for monetisation may be treated as:

• misappropriation of commercial value
• unfair competition in digital content markets

II. SPC Case Law Examples (Relevant to Captioning/Subtitle Revenue Logic)

Case 1: “A Bite of China” Internet Dissemination Case

• Court: SPC-guided model case
• Issue: unauthorized online distribution of audiovisual work
• Principle:
  • Internet dissemination rights are protected as core copyright exploitation rights
• Relevance:
  • subtitles/captions form part of dissemination of audiovisual works
• Holding:
  • platform liable for unauthorized dissemination
     

Case 2: Music Copyright Society v. Douyu Network (Streaming Platform Liability)

• Issue: live streaming platform using copyrighted music without authorization
• Principle:
  • platforms earning revenue must ensure licensed content use
• Relevance:
  • subtitles and captioning monetisation treated similarly to streaming content monetisation
• Holding:
  • platform liable for infringement damages
     

Case 3: Yu Binhua v. Huaduo Network (Live Streaming Revenue Rights)

• Issue: revenue distribution in online streaming ecosystem
• Principle:
  • defines legal relationships between streamer, platform, and users
• Relevance:
  • analogous to subtitle creators vs platform vs rights holder
• Holding:
  • clarifies contractual and tort responsibilities in digital content monetisation
     

Case 4: Wu Xiaoqin v. Shaanxi Broadcasting Network (Bundled Media Services)

• Issue: bundling of digital broadcasting services
• Principle:
  • abuse of dominance + unfair trade practices in media distribution
• Relevance:
  • captioning/subtitle services bundled into subscription packages
• Holding:
  • bundling may constitute unfair competition
     

Case 5: CCTV International v. Tudou Network (Video Platform Copyright Case)

• Issue: unauthorized video distribution on platform
• Principle:
  • platform has duty to monitor uploaded audiovisual content
• Relevance:
  • subtitle tracks considered part of audiovisual exploitation chain
• Holding:
  • platform liable for failing to prevent infringement
     

Case 6: Henan Bee Industry v. Image Technology (Digital Licensing & Copyright)

• Issue: licensing of digital content and misuse of copyrighted material
• Principle:
  • strict interpretation of licensing scope in digital works
• Relevance:
  • subtitle/caption monetisation depends on licensing scope clarity
• Holding:
  • unauthorized use beyond license scope = infringement
     

III. Key Legal Principles Derived for Captioning Revenue Disputes

1. Revenue follows copyright ownership

If captions/subtitles are:

• part of licensed audiovisual work → revenue belongs to copyright holder
• independently created → may generate separate copyright claims

2. Platforms cannot monetise unlicensed subtitles

Even if subtitles are user-generated:

• revenue-sharing does NOT eliminate liability

3. Subtitle creation is often treated as derivative work

Requires:

• authorization from original rights holder

4. Safe harbor is conditional

Platforms must:

• remove infringing captions quickly
• have monitoring systems

5. Contract clarity is decisive

SPC repeatedly enforces:

• explicit licensing terms over implied rights

6. Digital media = integrated revenue ecosystem

SPC views captioning, streaming, and advertising as:

• unified commercial exploitation system

IV. Conclusion

Although the SPC does not treat “captioning revenue disputes” as a separate legal category, it consistently resolves them through:

• Copyright law (core framework)
• Contract law (licensing and royalties)
• Platform liability rules
• Anti-unfair competition principles

The six cases above show a consistent pattern:
👉 captioning revenue is legally inseparable from audiovisual copyright exploitation rights in China’s SPC jurisprudence.