2026-08-10 - LD The Hague - Samsung v. Maxell - UPC_CFI_769/2025
- Aktenzeichen:
- UPC_CFI_769/2025
- Datum:
- Spruchkörper:
- Court of First Instance - The Hague (NL) Local Division
- Art:
- Decision
- Parteien:
- Samsung Electronics Benelux B.V. , Samsung Electronics Co., Ltd., Samsung Electronics GmbH, Samsung Electronics France, S.A.S. v. Maxell, Ltd.
Kernaussage: 1.
2026-08-10 - LD The Hague - Samsung
v.
Maxell - UPC_CFI_769/2025
1. In the absence of any functional interdependencies that establish a
synergistic effect, a plurality of routine modifications that the skilled
person would each take as a next step and as a matter of routine, amount
to a mere aggregation of features that is obvious.
2. In case auxiliary requests limit the scope of protection of the patent
progressively, and the auxiliary request that limits the scope furthest is
not considered inventive, the previous auxiliary requests are also obvious
as these contain less distinguishing features.
notable
The Hague Local Division revoked the patent in its entirety and dismissed the parallel infringement action without reaching infringement. The granted claims lacked novelty because, on the Court's construction, the transmitted result of a single user operation is 'history information' — the claim was not confined to the single embodiment that described the characterising feature, and 'display' was held to cover audio and haptic output as well as visual output. All ten auxiliary requests fell for lack of inventive step over a single realistic starting point combined with a second document: the Court held that distinguishing features providing unrelated technical functionalities, each a routine next step, are a mere aggregation and cannot support inventive step in the absence of a synergistic effect (headnote 1, following the Munich Local Division in Promosome v BioNTech/Pfizer). Procedurally, the Court confirmed that where auxiliary requests limit the claim progressively, obviousness of the request limiting the scope furthest disposes of the broader ones (headnote 2). Costs were fixed on the parties' own agreement at EUR 400,000, split equally over claim and counterclaim and awarded in full to the fully successful defendants.
Nichtigkeitsgründe
Art. 138 EPCNovelty
Patent invalid (this ground)Art. 54 EPC · Art. 138(1)(a) EPC
“Claim 1 as granted is fully anticipated by D3 (US 2006/0263048 A1): the playback position transmitted on a 'throw operation' reflects the user's earlier operation of stopping playback and is therefore history information [55]-[59]. Independent claims 11 and 17 contain corresponding features, so the whole patent as granted lacks novelty [60].”
Inventive Step
Patent invalid (this ground)Art. 56 EPC · Art. 138(1)(a) EPC
“All ten auxiliary requests lack inventive step over D1 in view of D3 and the common general knowledge [78]-[130]. Only the handback functionality was a substantive technical distinction; it is taught by D3 and D1 par. 9 points the skilled person to it [86], [97]-[99]. The remaining features were implicitly disclosed or routine modifications forming a mere aggregation [100]-[128].”