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Anyone with young children, or grandchildren, must be familiar with Peppa Pig, the anthropomorphic pig with the plummy British accent, surrounded by a porcine family and a range of other animals. Originally produced in 2004 by the British animation studio Astley Baker Davies, it was subsequently acquired by the Canadian media company Entertainment One, with control later passing to Hasbro in 2019 when the US company acquired Entertainment One. The animation style is simplistic, and the characters look as if they could have been drawn by young children. It is wildly popular globally, which of course makes it a prime candidate for knock-offs.
While there is no copyright restriction on producing a cartoon series based on a family of pigs, or other animals for that matter, there are certainly protectable elements in an original production that could result in litigation if infringed. This is precisely what happened regarding a remarkably similar, and also popular (48 billion views worldwide) production about a wolf family. The show, known as Wolfoo, is produced in Vietnam by the animation company SConnect, which bills itself as a “beacon of innovation”. Hasbro disagreed, and in 2022 brought suit in England for copyright infringement. Although Wolfoo is about a wolf family, and is voiced (in English) by actors with an American accent, its storyline and animation style is remarkably similar to Peppa. It looks plagiarized, to say the least, but plagiarism is not copyright infringement. What is copyright infringement is SConnect’s use of Peppa Pig sound recordings, including character dialogue and sound effects, in creating a competing product.
This interesting case was recently highlighted in its newsletter by Copyrightlaws.com, a top-rated copyright education site offering information and courses for those interested in learning more about copyright. Various legal firms have also written on the case but one of the most comprehensive accounts is from Simkins LLP in London, based on the summary judgment ruling issued in June of this year.
Initial complaints against SConnect were for passing off and copyright infringement, including breach of trademark, but were then narrowed down to charges of infringement of copyright in sound recordings. This was arguably the most straightforward to prove. At issue was not the copyright in the underlying sounds (which, for example, could have involved the voice actors), but the recordings themselves made by the Peppa Pig production company. The case had several interesting aspects. It depended on expert spectrographic analysis to identify the infringements (which proved irrefutable), the court allowed evidence based on “sampling” of a number of Wolfoo YouTube recordings rather than requiring proof that all Wolfoo productions before a certain date were infringing, and finally, the court’s injunction was applied internationally. With respect to this point, the Copyrightlaws newsletter noted that,
“The…injunction, which orders the removal of all existing Wolfoo videos (over 30,000) and prohibits the uploading of future videos, applies not only to the UK as a jurisdiction but also to the whole of the EU and to any countries covered by relevant international treaties and conventions. Additionally, the court stated that the injunction is also flexible enough to apply to any nations that might join such treaties and conventions in the future. This provides incredibly broad coverage for this kind of injunction…”
(The newsletter adds it should be noted that this conclusion is case-specific and does not necessarily set a precedent for future lawsuits.)
It is this international reach I want to focus on, specifically the “why” and “how”.
The “why” is based on the “principle of similarity”, which, under certain circumstances, allows for the application of UK law to acts committed in foreign jurisdictions if the foreign laws governing those acts are similar to the law governing such acts in the United Kingdom. In the Peppa Pig case, there were two elements of alleged copyright infringement, reproduction (which the court accepted had taken place in Vietnam) and communication to the public, which in addition to the UK took place widely, (the EU, US, Canada, Bangladesh, Ghana, Hong Kong, India, Indonesia, Malawi, Malaysia, Malta, New Zealand, Pakistan, Singapore, Taiwan and Thailand were specifically mentioned). The defendant’s position was that since copyright laws are of national origin, and differ from country to country, British law and an English court ruling could not apply outside the UK, and moreover, the claimants (Hasbro) had not proven infringement under any foreign laws.
This argument failed. The court did not directly apply British law to jurisdictions outside the UK. Instead, it applied British law to infringements that–although they had taken place outside the UK–damaged a claimant that was registered and did business in Britain. A remedy for these damages could be widely applied because, based on the principle of similarity, all the jurisdictions in question had similar laws (with respect to infringement of the communication right), according to the English court. This included the EU, since the UK had aligned its copyright legislation with EU standards prior to Brexit. As for other countries, they adhered to relevant international conventions, such as the 1961 Rome Treaty and the World Performances and Phonograms Treaty (WPPT) which required them to protect such rights.
The location of where an infringement occurs is important with respect to judicial jurisdiction as Getty Images learned when it brought a copyright infringement case against Stability AI in the UK. While Getty proceeded with the case to mixed results, it dropped its primary copyright claim against the AI company because it was evident that the training (i.e. reproduction) had taken place outside the UK. The location of the AI servers where the reproduction takes place is not a definitive jurisdictional factor, however. In the case of Toronto Star v OpenAI, the Ontario Superior Court determined it had jurisdiction to hear the case despite the fact that the actual unauthorized reproduction (copying) took place outside Canada. It so ruled because there was a real and substantial connection between the nature of dispute, the parties concerned, and the jurisdiction of the court. For example, OpenAI does business in Ontario and its terms of service for Ontario users constitute an Ontario contract.
In the Peppa Pig case, the English court exercised jurisdiction because some of the alleged infringement (communication to the public) had taken place in the UK and a UK entity was pleading damages. The court determined that UK consumers were “targeted” because (among other factors) no attempt was made to geoblock UK viewers, and Wolfoo programs contained UK advertising. The defendants argued that Wolfoo was aimed only at US and Vietnamese audiences. Having established that it had jurisdiction, the court then extended its remedy in the form of an effective global injunction.
So much for the “why”. What about the “how’? How can an English court impose its decision on a Vietnamese company operating in multiple international jurisdictions? First, SConnect has assets in the UK which could be in jeopardy if it does not comply with the injunction, as the company would be in contempt of court. More significantly, there are practical distribution considerations. Wolfoo is largely distributed via YouTube, owned as I am sure everyone knows, by Google. And although Google/YouTube is not named in the injunction, it is not going to stick its neck out for a company like SConnect and thumb its nose at the English court, for the obvious reasons that it also has major commercial interests in the UK. That is not to say that Google would not resort to litigation to prevent what it saw as extraterritorial reach by a foreign court (see, for example, the Equustek case in Canada here, here, and here). That case went to the Supreme Court of Canada. But in the end Google lost—and complied.
SConnect claims the UK court decision will not affect its future development of the Wolfoo brand, despite its compliance with the injunction. If so, the company will need to move forward on the basis of true innovation, not free-riding and infringement. Peppa, the porcine snorter has demonstrated her global reach, not just in popularity among young children in many different cultures, but even when it comes to slapping down an errant wolf.
© Hugh Stephens, 2026. All Rights Reserved.
