2026-07-31 - LD Paris - Bostik v. Henkel France et al. - UPC_CFI_583/2025

The Paris Local Division declared the patent invalid in its entirety for added matter and dismissed the parallel infringement action without examining the accused products. The application as filed disclosed a single minimum value for the compound notion of bond strength, which the Court held necessarily implies that both the cohesive and the adhesive strength exceed that value; the granted claim recited the minimum for the cohesive strength alone and so embraced embodiments with an adhesive strength below it, an unallowable intermediate generalisation. That ground disposed of the patent, so the Court expressly declined to rule on insufficiency, novelty and inventive step, and did not examine the conditional auxiliary requests because none of them addressed added matter. On construction the Court held that a claim combining compositional features with post-treatment functional properties forms one indivisible whole, and construed the functional term 'non-resealable' by reference to its purpose: it is enough that the restored closure is significantly weaker than the original, so that a consumer can tell the package was opened. Costs followed the event under R. 118.5 RoP and Art. 69 UPCA.