Lifestyle Equities v SportsDirect: unregistered sub-licence losses still recoverable
Lifestyle Equities CVvSportsDirect.com Retail
- Court
- High Court
- Judgment
- 9 June 2025
- Citation
- [2025] EWHC 1417 (Ch)
Not registering a trademark licence can cost the licensee protection, but not the owner's right to claim its losses.
SportsDirect argued that losses suffered by Lifestyle Equities' unregistered sub-licensees could not be claimed at all. The High Court disagreed, and the trademark owner's damages claim survives.
What happened
Lifestyle Equities, which owns registered trademarks, had been fighting SportsDirect over trademark infringement for years. In a later stage dealing with how much SportsDirect owed in damages, Lifestyle Equities wanted to claim not just its own losses but losses suffered by companies it had sub-licensed to use its marks. The problem was that those sub-licences had never been registered on the UK trademark register, and the sub-licensees were not part of the court case. SportsDirect applied for summary judgment, asking the court to rule that none of those sub-licensee losses could be recovered at all.

What did the court decide in Lifestyle Equities CV v SportsDirect.com Retail?
The court held that losing the "protection of section 30" under section 25(3)(b) of the Trade Marks Act 1994 is personal to the unregistered licensee. It does not take away the trademark owner's own right, under section 30(6), to have licensee losses taken into account when claiming damages. The court also found that sub-licensees cannot join the case as claimants themselves, except to step in under section 30(6A), and that there is no deadline for a licensee to register late. Late registration can still fix the licensee's own position going forward. SportsDirect's application failed.
What we learned from this
- What I'd take from this is that failing to register a trademark licence doesn't automatically wipe out a damages claim, but it does limit what the licensee itself can do about it. If you hold a trademark licence, registering it promptly protects your own position directly rather than relying on the owner to claim on your behalf. If registration was missed, this case suggests registering late can still help going forward, though it won't fix everything retrospectively. Trademark owners bringing infringement claims may still be able to include losses suffered by licensees further down the chain, even unregistered ones.
Things to be aware of
- This was a summary judgment decision on a legal point, not a final ruling on how much SportsDirect actually owes.
The businesses involved
Lifestyle Equities CV
Trademark proprietor and licensor that brought long running infringement proceedings against SportsDirect over use of its registered marks.
SportsDirect.com Retail Ltd
Retailer that was the defendant in the infringement proceedings. Later renamed Frasers Group Trading Limited, with the SportsDirect.com Retail name reused by a separate, later-incorporated company unconnected to this case.
What happened next
- SportsDirect, by then renamed Frasers Group Trading Ltd, appealed the decision to the Court of Appeal, which heard the case as Lifestyle Equities CV v Frasers Group Trading Ltd.Source: Courts and Tribunals Judiciary website, May 2026
What others said about it
- Simmons & Simmons said the Court of Appeal's decision confirms that registering trademark licences is key to protecting a licensee's ability to recover losses.Source: Simmons & Simmons, June 2026
- Fieldfisher called the Court of Appeal's ruling a clear reminder that registering a trademark licence is necessary, not just administrative, to recover losses.Source: Fieldfisher, July 2026
How we can help
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This page is for information purposes only and does not constitute trademark advice or guidance. Summary drafted with AI assistance from the published judgment and checked by The Trademark Helpline (how we write these). Judgment: [2025] EWHC 1417 (Ch) on Find Case Law, published under the Open Justice Licence. Company details from Companies House; trademark counts from the UK trademark register. Last reviewed 27 October 2026. Report an error.










