Below, Prof. Willem Hoyng provides his unfiltered views on the decisions that were published on the website of the Unified Patent Court (“UPC”) last week. His comments offer a unique insight into the UPC’s case law, as he chairs the Advisory Board of the UPC and participated in drafting the Rules of Procedure of the UPC.
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15 October 2025 (published last week)
LD Milan, Insulet v EOFlow
Costs (after final decisions)
The Judge-Rapporteur (JR)
- In view of the litigation value set for the different actions, the recoverable costs have a total ceiling of € 1 million.
- If you do not appeal an interim award of costs then this is res iudicata and no further costs can be claimed with respect to the proceedings to which the interim costs decision relates.
- Costs based on redacted invoices from which do not show (precisely) what has been done, cannot be claimed.
- Costs related to personal circumstances of the representative (request for rescheduling hearing because of unavailability) cannot be claimed.
- All costs related to activities after the judgment (such as enforcement of the decision) cannot be claimed.
- Of the total sum claimed, € 360,772 remained in terms of recoverable costs. Having regard to proportionality, the JR awarded € 313,773.40, of which € 200,000 had already been awarded as interim costs.
Comment
- This case shows again how much money can be saved if parties agree on costs before the judgment. Parties must have spent considerable costs to fight about costs.
- The JR must also have spent considerable time calculating what is reasonable and proportionate up to euro cents!
- If parties continue to ignore the hints of the Court to settle on costs, I think that when the Rules are revised, a more efficient way of establishing costs should be implemented.
- In this case, for just enforcing the judgment, Insulet spent € 32,000! The JR ruled that this amount cannot be recovered JR because they are not covered by R. 150 RoP. Although € 32,000 is of course ridiculously high for enforcing a judgment, in most countries such costs (a few hundred euros) are recoverable and this Rule may also be reconsidered if the Rules are revised.
16 October 2025
Central Division Milan, Herbert Smith v Insulet/EOFlow
Request for the written submission and exhibits
Facts
Herbert Smith asked for access to the written submissions and exhibits of the Insulet v EOFlow case, giving as reason the desire to better understand the judgment for providing expert advice to its clients.
The JR
- After hearing the parties, the JR decides to give Herbert Smith access to the redacted versions of the submissions but not the exhibits, as this suffices to understand the judgment.
- With respect to the exhibits, the JR observes that if they are not referred to in the judgment they are irrelevant for understanding it. If they are relevant, then what the Court has said about them in the judgment is sufficient to understand the decision.
Comment
- I think that this is a good ruling as the standard phrase “better understanding of the decision” is, as all practicing lawyers understand, (usually) not the actual reason. The true reason is (in general) to see (for a client) what arguments and evidence were submitted.
- However, if you do have good reasons to know more (such as the content of expert reports etc.), you should come up with more than the standard explanation.
16 October 2025
Local Division Munich, Brita v Aquashield
Save an invalid patent
Facts
On 22 August 2025, the Local Division Munich revoked Brita’s patent and dismissed the infringement claims.
On 15 October 2025, Aquashield requested withdrawal of the revocation proceedings (R. 265 RoP) and did not ask for costs. Brita agreed.
Decision of the Court
Withdrawal allowed.
Comment
As the revocation decision was not final, the withdrawal results in the patent remaining valid.
There may be good reasons for both parties to use this road to settle: , for instance if the patentee has licenses or does not agree with the decision but does not want to spend the money for litigating an appeal, or thinks that it stands a better chance in completely new proceedings having learned from its defeat in this one. The claimant in the revocation action may be happy to avoid an appeal and, if it can continue selling (maybe under a royalty-free license), to cooperate and withdraw its claim for revocation.
17 October 2025
Local Division Munich, AX Wireless v Xiaomi
Extension of time
Facts
- In this case, among the four defendants, there are two Chinese companies which have to be served in accordance with the The Hague Convention, which takes time and often proves to be difficult.
- The representative of all four Xiaomi companies (two Chinese, one German and one Dutch) offered to accept service for the Chinese companies if the time limits for filing a preliminary objection and the defence for the German and Dutch companies are extended until the due dates for the Chinese companies.
- The claimant agreed.
The Court
The Court grants the request for extension of time, because overall it allows for a more expedient management of the case and consolidated written statements all due on the same day.
Comment
- Why did the US claimant bring this case in the very busy Local Division Munich and not in the less busy Local Division of The Hague (considering the Dutch defendant)? Probably because their representatives suggested that it was preferable for some reason. However, I wonder why.
- Such alignment of appearance for Chinese defendants and time limits makes sense. When the Rules are revised, one should think about a Rule which would make accepting electronic service for non-EU defendants by a representative attractive!
17 October 2025
Local Division The Hague, Abbott v Sinocare
Preliminary injunction proceedings
Facts
- Abbott started preliminary injunction (“PI”) proceedings on 4 July 2025 based on a Unitary Patent granted on 4 June 2025.
- The patent is about a continuous glucose monitoring system.
The Court
- The Court refers for claim interpretation to the principles laid out in the decisions by the UPC Court of Appeal in Nanostring v 10x Genomics (CoA_335/2023, decision of 26 February 2024) and the Enlarged Board of Appeal of the European Patent Office in G1/24.
- The parties did not state who the skilled person is, so the Court determines it.
- The claim is not limited to the embodiment of Fig. 34.
- The Court rules that the patent is novel, inventive and sufficiently disclosed (referring to the examples in the patent for the latter).
- The Court in these interlocutory proceedings verifies added matter only for claims 1 and 15. The defendant had not substantiated the argument for claim 15.
- The Court does not accept the non-infringement arguments based on a narrow interpretation of the claims.
- The Court does accept the possibility of irreparable harm, urgency as well as necessity.
- A declaration of infringement cannot be requested in PI proceedings.
Comment
- The patent was granted on 4 June 2025 on the basis of a priority application filed in 2011 and kept alive via divisionals which made sure that the patentee could tailor its claims to the infringing product. The outcome of this case shows that the patentee did a good job, as the non-infringement defence was based on a (very) narrow claim interpretation basically arguing that the claims were describing figure 34 of the patent. Such a “picture” interpretation is generally bound to fail.
- Of course such submarine tactics are only successful if you are able to avoid added matter (thus by filing very detailed priority applications). The Court was very practical, only dealing with these arguments to the extent necessary to find infringement with respect to claims 1 and 15.
- The Court can do so in PI proceedings as it does not decide infringement and validity but only predicts the outcome of the (later) proceedings on the merits. The outcome of PI proceedings is an interim order, not a decision. This also means in my opinion that you can base PI proceedings on an auxiliary request, as long as it is more likely than not that in proceedings on the merits, the claim of such request will be held valid.
- If the patentee is the only company which can put the product implementing the invention on the market and the infringer’s product will be the competing product, “irreparable” harm is almost a given.
20 October 2025
Central Division Paris, Meril v Edwards
UPC_CFI_189/2024; UPC_CFI_434/2024
Inventive step / public interest
Facts
- In May 2024, three Meril subsidiaries filed a revocation action against Edwards.
- Edwards counterclaimed for infringement.
- The patent was a third generation divisional granted on 28 February 2024 with a priority date of 5 December 2010, relating to a prosthetic heart valve and a delivery system for such.
- Meril argued invalidity on the basis of added matter, lack of novelty and inventive step.
- Edwards argued that its patent was valid, and filed 17 conditional auxiliary requests. It argued in the alternative that each of the dependent claims in combination with claim 1 of the patent or of the auxiliary requests was valid.
- The JR allowed a R. 263 RoP request for including a new (allegedly infringing) product to be added to the counterclaim and a further written exchange with respect to that product.
- Meril argued against an injunction based on proportionality considerations and/or exception for certain products and patient groups and/or a grace period.
The Court
- The Court does not stay the proceedings in view of the pending opposition proceedings, which was in any case not requested by the parties.
- The Court, referring to the front-loaded character of the proceedings and R. 44 RoP, agrees with the JR who refused a new line of argument in the reply on why claim 7 was invalid based on added matter.
- The Court agrees with the JR that arguments made by the defendant in its rejoinder were allowed, as they were a response to new arguments and evidence by the claimant. Similarly, new documents filed with the reply were allowed as they were raised in reaction to the defence.
- Visual aids such as slide decks during the oral hearing are allowed, even if they contain new terms or illustrations, as long as it does not amount to new arguments. They can be used as “further means to explain with greater immediacy technical aspects already sufficiently illustrated in the written proceedings” (see no. 49 of the judgment).
- The Court discusses the patent and interprets certain claim elements, citing the Court of Appeal in Nanostring v 10x Genomics (CoA_335/2023, decision of 26 February 2024). The Court does not accept the limited interpretation of claim features 1d, 1e and 1f by Edwards as it “is inconsistent with the only detailed embodiment discussed in the patent”.
- The Court follows the interpretation of the term “slack” by Edwards and states that Meril’s more limited interpretation “has no explicit or implicit basis in the patent”.
- The Court (without mentioning the gold standard) rules that certain dependent claims are invalid because of added matter and that the patent as granted is therefore invalid.
- Meril argued that the auxiliary requests (it counted with all the possible combinations more than 1,800) were not admissible because of lack of an explanation as to why they would comply with Art. 84 (clarity) and be valid. The Court finds, under the (complex) circumstances of the case, the 17 auxiliary requests be reasonable in number, adding that in any case, if there were too many, that could not lead to all the requests being inadmissible.
- The Court rules that auxiliary request 1 is not novel based on two publications (stating among others that certain claim elements are “implicitly disclosed”).
- Auxiliary request 2 is considered novel and inventive. With respect to inventive step the Court states the following:
a. The assessment of inventive step requires, first, the identification of the objective problem underlying the claimed invention, which must be carried out in light of the patent’s specification; second, the identification of the state of the art at the time of the claimed invention, which can be represented by one or more realistic starting points and is left to the initiative of the parties; and, finally, whether it would have been obvious for the person skilled in the art to arrive at the claimed solution.
b. A “holistic approach” – that is, a broader way of assessing non-obviousness by considering the invention as a whole, rather than just focusing upon isolated distinguishing features – appears, in general, to be more appropriate.
c. A realistic starting point is a document “of interest” for solving the objective problem. It may be assumed that realistic starting points, in general, are pieces of evidence which disclose the main relevant features of the challenged patent and for that reason have constituted the basis for the development of the inventive concept and/or which address the same or a similar underlying problem. - The Court finds infringement. With respect to the proportionality arguments, the Court, also referring to Art. 28(1) of the Agreement on Trade-Related Aspects of Intellectual Property (“TRIPS”), concludes that the normal remedy in case of infringement is an injunction, save where it would be disproportionate or unreasonably detrimental to the public interest. The fact that the infringing products are as good as the original one and thus provide more choice for the physicians is insufficient reason for not granting an injunction. This is different for the Octapro valve for aortic annuli larger than 30 mm, as this is the only product available on the market.
- In ruling so, the Court departed from the Munich Local Division which imposed certain conditions for the use of the Octapro valve for aortic annuli larger than 30 mm (so that the patentee would know what and how many were sold).
Comment
- Once again, clients should realize that if your representative suggests to start a revocation action in the name of companies of the group who sell or are involved in the sale of the possibly infringing product, this mean that in case the revocation action does not prevail, these companies are immediately confronted with an infringement counterclaim.
- When it comes to infringement, the so-called certainty for third parties plays a role.That being said, if (by way of example) you file a patent application in 2010 of 300 pages, you can obtain after many divisionals a patent in 2024 with a claim which never appeared as such before: if the 300 pages contain 40 different products which can be argued to be an invention but are never claimed as such, they still may become the subject-matter of a claim many years later. These submarine claims are considered as normal. I have not yet seen a UPC Representative arguing that a reasonable skilled person reading the 300-pages application, would not have read the eventually claimed invention into it, and that such submarine tactics violate the reasonable certainty of third parties. So the claimed subject-matter may well be in the original application, although not qualified as invention (yet)! Therefore, if you want to put a product on the market, do not rely on the fact that it does not fall under the claims of the patent application.
- The case is also another lesson about the front-loaded character of the UPC proceedings. Make sure you do not start before you have fully prepared the case including finding and considering all the arguments the defendant could make. For the Statement of Defence, this should mean hard work as of day 1. This case is again a good example of what can go wrong even if the Court is reasonable in applying the front-loaded principle (as in this case).
- Visual aids can be used during the oral arguments but I think they should be sent to the other side and the Court at least one or two weeks before the oral hearing and should not contain new facts or arguments. I have the impression that the Court was in this case very (and perhaps too) lenient (see my quote from the Court decision under 4 above).
- We know by now that the Central Division in Paris does not apply the problem-solution approach (which – as readers may have noted – I applaud). I agree with the more holistic approach compared to the rather rigid problem-solution approach.
- As to the carve-out to the injunction, the Court disagrees with the Munich Local Division. Although the way the Munich Division formulated the exception may be a bit too strict, I think that the unconditional exception granted by the Paris Division goes too far. These products are not consumer products and the Court could have at least ordered that the infringer has to report each month the numbers sold and to whom, in order to ensure a certain control.
21 October 2025
The Hague Local Division, Amycell v X
The unwilling defendant
Facts
- This decision concerns the proceedings on the merits after the Court had granted a PI. These proceedings have to be brought, otherwise the defendant can ask for revocation of the PI (R. 213 RoP).
- After the Registry was not been able to serve the Statement of Claim for 3,5 months, the Court allowed “alternative service” (R. 275 RoP).
- Such alternative service was ordered after the representative in the PI proceedings told the Registry that he had not been appointed as representative in the proceedings on the merits. Several efforts of service failed because the defendant refused to accept the letters/packages, etc.
- After the alternative service, the deadline for the Statement of Defence was 25 February 2025.
- On 4 March 2025, the Statement of Defence was uploaded by the previous representative with a request for reestablishment of rights, which was refused.
- The defendant filed 7 more applications without the permission of the Court!
- Thereafter the claimant asked for a decision by default.
- The Court cites R. 277 RoP which specifies the conditions for a decision by default, basically ensuring that the defendant was made aware of the Statement of Claim.
- The Court stated that the claim was well-founded, relying on the decision in the PI proceedings.
- The Court issued the default judgment.
Comment
- Quite some effort and money was spent on this unwilling Polish defendant which did everything to frustrate the service of proceedings. In the end, his Polish representative, who first refused service by electronic means, was late in filing his Statement of Defence and spent further money of his client with seven useless applications.
- It all shows that companies should seek an experienced representative who would advise that playing hide and seek only costs money and leads nowhere, especially as judgments (also for costs) can be enforced in Poland as an EU country.
- The hurdle for obtaining a default judgment in the UPC is rather high. Not only are significant efforts required to make sure that the defendant knows about the Statement of Claim (see R. 277 RoP), but the Court also has to (seriously) look into the case and make sure that the claimant is right (R. 355.2 RoP), which is a higher threshold than in some national jurisdictions.
- Finally, such default judgment is not the end of the road for the claimant. They first have to try to serve the decision of the Court on the defendant. Then the defendant can file an application to set aside the decision by default and, if they do so, the real proceedings can finally start.
- Normal people (I mean non-lawyers or -patent attorneys, but people who do something else to enable them to pay these lawyers and patent attorneys) will surely be at a loss understanding all this madness!
21 October 2025
Local Division Hamburg, Occlutech v Lepu
PI proceedings (imminent infringement?)
Facts
- Defendant 1, a Chinese company, obtained a CE marking for its occlusion device and presented its products in trade fairs/conferences in Europe (Paris and Frankfurt).
- The patentee requested a preliminary injunction.
- The defendants disputed that there is “imminent infringement”, arguing that they are not infringing and that the patent is invalid.
The Court
- The Court states that the defendants did not dispute the international jurisdiction which follows from Art. 7(2) jo. Art. 71(b)(2) Brussels I Regulation (“BR”).
- The Court refers to the decision by the Court of Appeal in Boehringer v Zentiva (UPC_CoA_446/2025, decision of 13 August 2025) with respect to the question of whether there is imminent infringement.
- Obtaining a CE mark approval is an indication of an imminent infringement. This is certainly the case as the defendants were showcasing their products at a Frankfurt trade fair.
- The Court finds (with an extensive reasoning) that the patent is (more likely than not) valid and infringed and that all the other requirements for a PI (urgency, necessity, weighing of interest of the parties) are fulfilled and that there is no reason to impose a security.
Comment
- The claimant avoided the difficulties of serving a Statement of Claim on a Chinese defendant by having it served at a trade fair.
- I do not understand why there was so much discussion about the question of “imminent infringement” because based on the facts it seemed very clear that infringing acts had already taken place, especially in the light of the decision of the Court of Appeal which held that “offering” should not be considered in the legal sense of the word but in the economic sense.
- The question was whether registering a CE marking for medical devices (which, as opposed to a marketing authorization, is not a decision of an administrative body but a unilateral act by a party) is as such sufficient to qualify as “imminent infringement”. I think it should be. The difference with a generic drug company obtaining a marketing authorization is that further administrative measures are necessary (such as “price reimbursement”) before marketing is possible. This is not the case with the registration of a CE marking. Thereafter the medical devices can immediately be marketed in the EU. In both cases, I think it should be possible to try to prevent the start of sales of infringing products: the best method for me seems to be that the patentee write to the company which is suspected of starting infringing activities, asking for an undertaking not to do so or promise to give two weeks’ notice before starting to sell. I think that, in absence of a positive answer, the UPC will accept (like the UK courts) the risk of imminent infringement.
22 October 2025
Local Division The Hague, Abbott v Sinocare
No infringement
Facts
Same facts as in the PI decision of 17 October 2025 mentioned above (UPC_CFI_624/2025) but here a different patent was invoked.
The Court
With respect to this patent: no infringement.
Comment
This patent was granted on 26 July 2023. One can see how important it can be to keep a divisional alive. The patent in the decision of 17 October 2025 was granted on 4 June 2025. When the claims of the latter were drafted, the Sinocare device was probably known and the claims could be tailored to that device because there was sufficient basis in the original application of 31 August 2009 (which was kept in the subsequent divisionals)!
23 October 2025
Central Division Milan, bioMérieux v Labrador
Revocation proceedings
Facts
- bioMérieux UK started the revocation on 30 August 2024.
- In the infringement proceedings brought by Labrador, the bioMérieux companies raised the invalidity as a counterclaim which was referred to the Central Division.
- In this case, the Court deals with both cases and the JR has established that the arguments are the same.
- Labrador decided to defend only claim 9 and 14, and filed 7 auxiliary requests.
- An interim conference was held on 14 July 2025, in which bioMérieux indicated on what attacks it would concentrate during the oral hearing.
- Parties agreed on costs at the amount of € 600.000, but disagreed whether this amount (the ceiling of recoverable costs) should be awarded for the two cases or for each of the cases.
The Court
- The Court started with a summary of the outcome: validity of auxiliary request 3. In that summary the Court made the following remarks:
“bioMérieux filed about 50 invalidity attacks, more than 12 added matter attacks, 3 novelty attacks, 1 insufficiency attack and 6 different starting points for 30 inventive step attacks. (…) Now that bioMérieux has identified the attacks to be discussed below as the most promising and those attacks do not affect the validity of Auxiliary Request 3, it will be assumed that the other, less promising, attacks on the validity of the third Auxiliary Request, do not do so either.” - The Court refers to R. 44 RoP (which states what is necessary to make a revocation argument) and R. 104 RoP (the JR can ask to limit the attacks and auxiliary requests to make their assessment mor manageable or test them in logical order).
- The Court accepts the first three auxiliary requests, which are, contrary to what bioMérieux argued, clear enough (Art. 84 EPC) and have basis (Art. 123 (2) EPC). The Court states that the auxiliary requests are clear “especially if it is taken into account that the skilled person should try with synthetical propensity, i.e. building up rather than tearing down, to arrive at an interpretation of the claim which is technically sensible and takes into account the whole disclosure of the patent. The patent must be construed by “a mind willing to understand, not a mind desirous of misunderstanding”.
- Referring to the principles laid down by the Court of Appeal the Court, the Court concludes that the main request (the original claims 5 and 14) and auxiliary request 2 contain added matter and that claim 1 of auxiliary request 1 is not novel and that auxiliary request 3 is valid.
- During the interim conference, bioMérieux accepted to identify two documents for the most promising novelty attacks and three different starting points for inventive step attacks.
- The Court dealt with these arguments and refused bioMérieux to bring new grounds for added mater during the oral hearing.
- As to the assessment of inventive step the Court stated the following (see 11.1 of the judgment):
“The assessment of inventive step must be carried out in accordance with Art. 56 EPC, which states that “[a]n invention shall be considered as involving an inventive step if, having regard to the state of the art, it is not obvious to a person skilled in the art”. An objective approach must be taken to the assessment of inventive step. The subjective ideas of the applicant or inventor are irrelevant. Inventive step is to be assessed from the point of view of the skilled person on the basis of the state of the art as a whole, including the skilled person’s common general knowledge. The skilled person is assumed to have had access to the entire publicly available art on the relevant date. The decisive factor is whether the claimed subject matter follows from the prior art in such a way that the skilled person would have found it on the basis of that person’s knowledge and skills, for example by obvious modifications of what was already known. In order to assess whether or not a claimed invention was obvious to a skilled person, the court can follow the problem and solution approach (PSA) as also used by the EPO, as a tool to assess obviousness, but nothing prevents the Court from following a different approach. Any approach in fact would render the same result in this case, as follows from the below.” - In conclusion the Court upheld the patent according auxiliary request 3 and awarded 2/3 (€ 400.000) of the ceiling for costs to Labrador.
Comment
- A showcase example of how the UPC should deal with cases:
a. The case started on 30 August 2024 and was made more complex by the addition of the counterclaim in October 2024. Nevertheless, the oral hearing took place on 12 September 2025 (a year after the start) after a timely interim conference in July 2025. I note that the busy German Divisions do not hold such conferences or if they hold them, it is shortly before the oral hearing;
b. a decision 6 weeks after the oral argument, with the total length of the proceedings being less than 14 months;
c. starting the decision with a short, clear (also for non-specialists) understandable summary of the decision;
d. not accepting patent attorney/EPO tactics of introducing more than 50 invalidity attacks, trying to make court proceedings unmanageable (!);
e. making sure that parties agree on costs, avoiding costly and time-consuming cost proceedings;
f. a very detailed high quality analysis of the (best) invalidity attacks resulting in an, in my opinion, convincing well-reasoned decision. - It is interesting to see that Labrador only defended two claims. This made their task less complicated and allowed them to concentrate on the truly relevant claims for their infringement case. This seems a good strategy. You even wonder whether it is sometimes smart to do so via central limitation proceedings before you start an action at the UPC, which allows you also to even tailor your claim to the infringing product if necessary (and if you have enough basis!).
- Also patent attorneys who want to litigate in the UPC should learn not to run each conceivable (or even inconceivable) invalidity argument but to make a selection before you start, and only run the best arguments. These arguments should be able to convince a court of law – which selection may require (considerable) litigation experience. Quite frankly, if you need 50 different invalidity attacks to invalidate a patent, any neutral observer would be immediately inclined to think that your case may not be the strongest. What is also unhelpful is a rather uncooperative attitude if the JR tries to make the case manageable (such as stating that the Court should choose the best invalidity arguments)! By now also each representative should know that you cannot bring new invalidity arguments during the oral hearing.
- It is not a surprise (and seems perfectly reasonable) that you do not get twice the ceiling of recoverable costs if the two cases (revocation and counterclaim for revocation) are the same.
- I think that the approach to inventive step (which I cited verbatim above) is the preferred more holistic approach to Art. 56 EPC.
- I had already criticized the Milan Central Division for accepting secrecy with respect to lawyers’ invoices and I applaud the decision to refuse the (quite frankly ridiculous) request to keep also the fact secret that parties agreed to settle at the ceiling for costs.
- I warn the user of the system that the amount of € 600.000 does not say anything about the total costs because it was based on the ceiling of recoverable costs. However, you find a further indication that bioMérieux argued for a doubling of the ceiling. So I assume their costs for the representation by a UK patent attorney (UK fees are in general considered the highest in Europe) must have been at least 1.2 million. In the end they were lucky that the Court did not grant their request to double the amount, and they had to pay Labrador only € 400.000 instead of € 800.000!
- Potential users of the system should be aware that the UPC is not cheap, and that you should carefully choose your representative and make sure that you have a first class experienced team with reasonable fees and recall not to be penny-wise, pound foolish.
– All comments above are Prof. Hoyng‘s personal opinions –
For all decisions of the UPC’s Court of Appeal from the start in 2023 until 1 January 2025, Willem Hoyng’s more comprehensive summaries and comments are bundled in the book “Case law – Court of Appeal of the UPC 2023-2024”.