On 3 March 2026, the Honourable Mr Justice Saini handed down judgment in Infinni Innovations SA v OFMS Ltd & Ors following a 3-day hearing in the Commercial Court.

Arnold Ayoo and Kendya Goodman represented the Defendants in contesting the continuation of an injunction granted ex parte to restrain an alleged breach of confidence in a novel context.

The underlying dispute concerns the “OnlyFans” social media ecosystem and specifically, the data held by customer relations management (“CRM”) platforms used by agencies to communicate with fans on behalf of OnlyFans creators. The judgment contains an explanation as to how the OnlyFans business model works, and the data generated within and related to that platform.

The Defendants are alleged to have perpetrated a cyberattack which unlawfully exfiltrated information from the Claimant’s CRM platform, including “fan notes” and “scripts” used for the purposes of interactions between subscribers and content creators on OnlyFans. The Defendants contend, amongst other things, that the relevant data is owned by the agencies which represent the content creators and that these agencies authorised the transfer of that data.

Whilst interim injunctive relief was continued until trial, the Court was persuaded to narrow the terms of restraint prescribed by the injunction principally because of its effect on the Defendants' clients and third parties, including content creators. The Court also declined to order a disclosure affidavit in the wide-ranging terms sought by the Claimant and instead ordered the provision of affidavit evidence in modified form. In so ordering, the Court helpfully clarified the test for ancillary disclosure affidavits at an interim stage.

The claim will now proceed to trial. Arnold and Kendya are instructed by Waleed Tahirkheli of Eldwick Law.

Read the judgment in full: Infinni Innovations SA v OFMS Ltd & Ors [2026] EWHC 470 (Comm)