Question juridique clé
Whether SSR owed additional remuneration for reports created before the written contract, despite the absence of an express copyright clause in the earlier oral arrangements.
Solution extraite
No additional remuneration was due; the reports were at least tacitly licensed for broadcast, and the claimant did not prove a separate copyright fee agreement.
Motifs extraits
The court held that copyright transfer or licensing may be concluded tacitly. Given the purpose of the commissions, the invoices without reservation, and the parties' conduct, SSR was authorized to broadcast the reports. At minimum, the purpose of the contracts required a licence, not an exploitation right reserved to the author.