On June 24 2025, the District Court of New Taipei City rendered a judgment against the popular legal search engine Lawsnote, finding the legal-tech startup liable for copyright infringement by reproducing the description of Taiwan’s legislative history compiled by Lawbank (111-Chi-Su-Zi No. 8).
Background to the case
Lawsnote was founded in 2016 by Guo Rongyan, an attorney, and aims to provide innovative search services for the legal industry. Meanwhile, Lawbank, established in 1986, is one of the most prominent databanks in Taiwan and known for its comprehensive legal research resources.
According to the judgment, between 2018 and 2019, Ray Hsieh, another co-founder of Lawsnote, developed and deployed six web crawlers to automatically extract data from the database of Lawbank, including laws and regulations, respective attachments and forms, and summaries of Taiwan’s legislative history. Lawbank discovered the unauthorised reproduction and filed a lawsuit in 2021.
The case primarily centres on two main issues:
Whether the scraped content of Taiwan’s legislative history is eligible for copyright protection; and
Whether Lawsnote’s use falls under fair use.
The court ruled against Lawsnote on both.
Analysis of the ruling
On the issue of copyrightability, Lawsnote argued that the legislative history it downloaded, which totalled 98,068 files, should not be eligible for copyright, and that even if such descriptions are copyrightable, Lawsnote should not be liable under the doctrine of merger.
The court disagreed, elaborating that the threshold for copyright protection is low, and that Lawbank’s selection, arrangement, and presentation of the legislative history demonstrated the minimum degree of creativity that could meet the requirement. As to the defence of merger, the court rejected Lawsnote’s arguments, noting that other legal databases described the legislative history differently, demonstrating that expressive choices were not limited.
On fair use, the court weighed the following factors:
The purpose of the conduct;
The nature of the work;
The amount and substantiality of the work used; and
The impact on the market.
Citing the fair use analysis in Thomson Reuters Enterprise Centre v Ross Intelligence (the United States District Court for the District of Delaware, 2023), the court found Lawsnote’s use was commercial in nature. By using a crawler to download bulk data from Lawbank, Lawsnote copied and reproduced 100% of Lawbank’s copyrighted content.
Lawsnote argued that the policy should favour public access to the content of the law, and that its search-focused platform was different from Lawbank’s model. The court dismissed these arguments, reasoning that Lawsnote gained an unfair competitive edge by avoiding years of effort and costs in compiling the data, which harmed Lawbank’s market. Thus, the court found Lawsnote’s conduct did not constitute fair use, and Mr Guo, Mr Hsieh, and Lawsnote should be jointly liable for infringing Lawbank’s copyright.
Key takeaways
While the judgment is not final and it remains uncertain how the case will evolve, this case nonetheless offers several noteworthy insights regarding copyright infringement issues.
First, one should always verify the source of the content. Using licensed materials may be time-consuming but safer. Second, fair use is less likely to apply where there is mere wholesale copying without any creative contribution. Lastly, while this case does not involve using copyrighted materials for AI training, it provides a useful preview of how courts may approach future disputes over bulk data scraping. The purpose and character of use, and the impact on the original market, will likely remain the most critical fair use factors.
