UPC Analytics
ENDE
Overview · Filed: —

ACT_19746/2024

Wireless power receiver and method of manufacturing the same

InfringementMain Infringement ActionHamburg LDInfringement Action—
OverviewDecisionsReasoningCitationsDocumentsTimeline
Coverage: Partial.Reasoning extracted with partial coverage — some sections may be incomplete.
Plain-English summary

Nera Innovations Ltd. (a patent assertion entity that acquired the patent from Scramoge Technology Ltd., which in turn acquired it from LG Innotek) sued Xiaomi entities before the Hamburg Local Division for infringement of EP 2 642 632, a wireless power receiver patent. The court found the patent as granted invalid but maintained it in amended form under auxiliary requests 1 and 2; the infringement action was dismissed because the amended claims were not infringed, and the revocation counterclaim was partially granted to the extent of invalidity beyond auxiliary requests 1 and 2.

Accepted arguments
What the court agreed with — by party.

  • Patent EP 2 642 632 in its main claim form is invalid for lack of novelty/inventive step

    RespondentLegal basis: Art. 54, 56 EPC

    Note: The Hamburg Local Division upheld Xiaomi's invalidity attack, finding the patent as granted could not be maintained in its original form; the infringement action was dismissed as a result.

  • Intermediate generalisation constitutes inadmissible extension where a term in the claim wording was dropped that was still present in the requested version

    RespondentLegal basis: Art. 123(2) and (3) EPC

    Note: The court found that dropping a term present in the requested version but not in the final claim constitutes an inadmissible intermediate generalisation, establishing added-matter as a ground for invalidity.

  • Prior art with comparable function but different application field (NFC antenna resonance frequency) does not constitute prior art the skilled person would consider for solving the problem of the wireless power receiver patent

    ClaimantLegal basis: Art. 54, 56 EPC

    Note: The court held that a document directed to adjusting resonance frequency of an antenna in NFC receivers is in a different field from building a wireless power receiver for charging, so the skilled person would not consult it when seeking a solution to the problem posed by the patent in suit.

Rejected arguments
What the court did not agree with — and why.

  • Patent as granted is valid and infringed by Xiaomi's wireless charging products

    ClaimantLegal basis: Art. 54, 56 EPC; Art. 25 UPCA

    Reason: The patent in its main claim form was found invalid, requiring amendment to auxiliary requests 1 and 2; in the amended form the specific accused Xiaomi products were not found to infringe.

  • Number of auxiliary requests is unduly burdensome on defendants

    RespondentLegal basis: R. 30.1(c) RoP

    Reason: The court held that where the core of the auxiliary requests is small, even a high number of requests does not pose an unreasonable burden on the opposing party under R. 30.1(c) RoP.

Key legal principles
Doctrines and rules cited in the reasoning.
intermediate generalisation as inadmissible extension under Art. 123(2) and (3) EPCprior art must be in same technical field or one skilled person would consult for the problem posednovelty and inventive step under Art. 54 and 56 EPCauxiliary requests admissible even if numerous where their core is smallpatent partially revoked and maintained in amended form (auxiliary requests 1 and 2)

Browse other cases on this principle.

Claim construction notes

The court's analysis of auxiliary requests 1 and 2 resulted in a maintained claim 1 requiring a substrate of 'a predetermined shape corresponding to a shape of the connecting unit' with a receiving space formed therein, connecting unit terminal connections specified. The invalidity of the main claim was based on novelty/inventive step grounds; the added-matter analysis related to what features could be dropped from or combined across different claim versions.