at a sitter pays the photographer for
prints, though he has not commissioned the sitting, would not vest the
copyright in him.

25. The "Living Pictures" case in 1894 (_Hanfstangel_ v. _Empire
Palace_) was a curious one. The Empire music-hall in London produced
some _tableaux vivants_, representing certain pictures, of which Messrs
Hanfstangel owned the copyright, and an action was brought by them for
an injunction. The courts of chancery and of appeal decided against the
plaintiffs, on the ground that a reproduction of a painting must be by a
painting or something cognate; but in an action for infringement, though
the view already given was confirmed, the plaintiffs succeeded so far as
the backgrounds to the grouping were concerned. Meanwhile two newspapers
had published sketches of the same _tableaux vivants_, and Messrs
Hanfstangel brought actions for infringement (_Hanfstangel_ v. _Newnes_,
and v. _Baines_, 1894). Mr Justice Stirling found for the plaintiffs,
but on appeal, and finally in the House of Lords, this decision was
reversed.

Designs.

26. _Copyright in Designs._--An act of 1787 first gave protection to
printed designs on linen and cotton fabrics; and in 1839 a further act
included designs on animal fabrics, or mixed animal and vegetable
fabrics; while in the same year another act protected designs for
manufactured articles. These acts had been preceded in France by laws of
1737 and 1744 creating a property by law in manufacturers' designs. The
British law, which in various acts established a copyright (a) in
ornamental and (b) useful designs, was in 1883 consolidated in the
Patents, Designs and Trade Marks Act, with amending acts up to 1888; and
these acts were further consolidated and amended by an act of 1905. See
TRADE-MARKS and PATENTS.

BRITISH IMPERIAL COPYRIGHT BILL OF 1910

The consolidation of the British copyright law, not only in the United
Kingdom but in the Dominions, and its amendment so as to include the
recommendations of the Berlin International Convention of 1908, were the
objects of a government bill introduced into parliament by the president
of the Board of Trade on the 26th of July 1910, discussion on which was
reserved for a later period in the year. The passing of this bill,
though the date of it was uncertain owing to the peculiar circumstances
of English politics at the moment, was practically assured by the facts
that, apart altogether from the crying need for a rev