AGA Rangemaster Group Ltd v. UK Innovations Group Ltd
On 15 December 2025, the Court of Appeal delivered a decision in the case of AGA Rangemaster Group Ltd v. UK Innovations Group Ltd (UKGI), and another concerning the sale of genuine but modified goods (refurbished or pre-used).
The dispute arose after UKIG began taking second-hand fossil-fuel AGA cookers and converted them to run on electricity, incorporating UKIG’s own control panel in place of the AGA control panel, and retaining AGA branding. On its website, UKIG referred to the goods with terms like ‘an eControl AGA’, and in a range of ‘AGA colours’.
AGA brought proceedings, alleging trademark infringement and copyright infringement of its design drawing for its control panel.
The Court of Appeal concluded that UKIG’s presentation of the goods gave a false impression of a commercial connection between AGA and UKIG (which UKIG should have done more to actively dispel), but that UKIG’s control panel did not infringe AGA’s copyright in its design drawing because UKIG did not reproduce the drawing itself - but rather created an object based on the drawing.
How can brands protect themselves from copyright infringement?
For brand owners, this decision emphasises the need to monitor the activity of those selling refurbished or pre-used versions of your goods. The court in this case did not find that such use is unlawful, but rather that such use must not give a false impression of a commercial connection between the brand owner and the secondary seller. Importantly, each case turns on its own facts.
How can sellers mitigate the risk of a copyright breach?
Businesses seeking to sell modified versions of third-party goods must tread a careful line in how they use the third-party trademark. There are obvious commercial advantages in drawing attention to the origin of the goods, and this can be done lawfully - but you need to be aware that if you cross the line, you could easily find yourself in legal proceedings.
What can brand owners and sellers do to protect and respect the third-party trademark?
To mitigate the risks highlighted by this decision, businesses should consider the following:
- For brand owners: Monitor the secondary market and the use to which third parties are putting your brand. Be prepared to take action if the third party crosses the line, causing potential customer confusion.
- For businesses using third-party brands: Carefully review your naming conventions, documentation, online content, and advertising material. You may well be entitled to use the third-party brand name, but extreme care must be taken not give a false impression of a commercial connection between you and the brand owner. This particularly applies when seeking to use a product name which features the third-party brand name.
Our Intellectual Property specialists can assist you in reviewing your product designs, assessing trademark portfolios, and addressing potential disputes with competitors. Whether you’re seeking to protect your brand or introduce a new product, we’re here to help ensure compliance and safeguard your commercial interests.
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Please be advised that this is an update which we think may be of general interest to our wider client base. The insights are not intended to be exhaustive or targeted at specific sectors as such, and whilst we naturally take every care in putting our articles together, they should not be considered a substitute for obtaining proper legal advice on key issues which your business may face.