Different legal systems have different approaches to the boundary between infringement and permissible usage of copyright works. UK law - copyright infringemen

Different legal systems have different approaches to the boundary between infringement and permissible usage of copyright works. UK law - copyright infringement is generally based on the concept of substantial reproduction of the original. On the basis of the similarity between the two, there was substantial reproduction. The main issue in the Red Bus case was over proof of copying of the specific work (on the basis that the work in question had been created by numerous photographers over the years (so how can you prove the specific work of the claimant was copied?)). US law - more flexible in the sense of avoiding infringement where the use of the work in a new light is sufficiently transformative. The linked article from the OP shows a good example in the combination of four separate shots to create a new work. The question would be whether the Instagram reproductions are sufficiently transformative. Perhaps the reproduction of one photo on its own is not sufficiently transformative. Another point of interest is that the person depicted in the photo may not be the owner of the copyright with a suitable cause of action (unless you're talking about selfies of course). I'm sure it would make for an interesting case!