2026-04-10 - LD Paris - SharkNinja v. Seb - UPC-CFI-0001594/2025

ENGLISH: The lack of novelty may stem from what is explicitly clearly, immediately and unambiguously disclosed, in the opposed prior art-document. But it also may be implicit when a person skilled in the art would objectively consider as necessarily implied in the explicit content of a prior-art document or would arrive, inevitably and without any reasonable doubt, at the result falling within the scope of the Claim by applying the teaching of the prior-art document.

Preliminary injunction application dismissed. The Paris LD found all asserted claims (1, 2, 4-8) of EP 3 689 198 (cooking device with dual-lid system for air-frying and pressure cooking) more likely invalid than valid for lack of novelty over Chinese utility model CN 202312830 (Tredy). The court applied an implicit disclosure doctrine: although CN 830 did not explicitly describe an 'air-frying mode,' the skilled person would necessarily understand the device as an air fryer because the figures disclosed all essential elements. The fan, while not visible in Fig. 2, was necessarily implied by the presence of an electric motor with a downward-pointing axis. Amended claims (Claims 1+8 combination) addressed per CoA UPC_CoA_898/2025 (Onward v. Niche) but irrelevant since both independently invalid. Interim costs of 120K EUR awarded to SEB for withdrawn EP 201, applying CoA 50% ceiling rule from Meril v. Edwards.