Andrew Bell, an engraver, included pages from James Clark's book in the Encyclopedia Britannica without permission. James Clark claimed that he had the copyright to the information, but Bell argued that the statute of limitations had expired on the claim. The case had originally been heard by a Lord Ordinary who had required Bell to return the pages to Clark. However, Bell appealed the statute of limitations issue to the higher court, which agreed with him that it was possible Clark's claim to the material had expired. As a result, the case was remanded to the Lord Ordinary to reconsider the penalty he had imposed requiring Bell to return the pages to Clark.

Note: Clark is indexed as "Clerk" in the digest.

Published Reports

William Morison, The Decisions of the Court of Session (1811), pg. Literary Property Appendix page 8