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UPC CFI 1594/2025
Nov 14, 2025·EP3689198 +1 more: COOKING DEVICE AND COMPONENTS THEREOF
- Case details
- StatusOral PhaseActionProvisional measuresCategoryProvisional Measures
- Parties
- RespondentsReps: Thomas Bouvet; Colin Devinant; Célia Benmesbah
- Division
- Paris LD
- Technology
- Electric Techniques
- Language
- English
- First decided
- Apr 10, 2026
Claims
At issue1, 2, 4, 5, 6, 7, 8
Notes: In provisional measures proceedings, the Court found on the balance of probabilities that claims 1, 2, 4, 5, 6, 7, and 8 of EP 3 689 198 are more likely than not invalid for lack of novelty over CN202312830U (CN 830) and/or WO2015062197A1 (WO 197). Claim 4 was deemed invalid without contested argument from claimant. The fallback combination of Claims 1 and 8 was considered but rejected as irrelevant given both claims were independently found more likely invalid than valid. EP 3 689 201 was withdrawn by claimant before oral hearing on 17 February 2026 and no substantive ruling was made on it.
Decisions
- 2026-04-10PI deniedPreliminary injunctionApplication for provisional measures
The Paris Local Division dismissed SharkNinja's application for provisional measures based on EP 3 689 198, finding it more likely than not that all asserted claims (1, 2, 4-8) are invalid for lack of novelty over prior art CN202312830U (CN 830). SharkNinja had previously withdrawn its provisional measures request concerning EP 3 689 201. SharkNinja was ordered to bear SEB's legal costs and to pay an interim costs award of EUR 120,000 corresponding to the EP 201 portion of the proceedings.
Legal issues:Novelty of claims 1, 2, 4-8 of EP 3 689 198 over CN202312830U (CN 830) and WO2015062197A1 (WO 197)Implicit disclosure in prior art — whether a fan for air-frying is implicitly disclosed by CN 830 Fig. 2Claim interpretation of 'to couple' (direct vs. indirect coupling of second lid)Claim interpretation of 'to cover' (lid covering the hollow chamber opening)Admissibility of fallback claim combination (Claims 1 and 8) in provisional measures proceedingsCosts allocation following partial withdrawal (EP 201) and dismissal (EP 198)Interim award of costs under R. 211.1(d) RoP
Documents
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| Receipt | 2026-05-10 | Not public |
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Accepted arguments
What the court agreed with — by party.
CN 830 discloses all features of Claim 1 including an air-frying mode, because a skilled person would understand the 'three-dimensional grilling' burner in CN 830 as an air fryer function, and would implicitly read a fan from the electric motor with downward-pointing axis shown in Fig. 2
RespondentLegal basis: Art. 54 EPC; Art. 138(1)(a) EPC; R. 211.2 RoPCN 830 implicitly discloses a bayonet coupling for Claim 2, as teeth visible in Fig. 1 would be understood by a skilled person as part of a bayonet coupling
RespondentLegal basis: Art. 54 EPCClaims 5 and 6 are invalid for lack of novelty over CN 830, which discloses an electric motor with axis for a fan (Claim 5) and, given motor/fan/heating element positions, the air movement device draws air through the second heating element (Claim 6)
RespondentLegal basis: Art. 54 EPCClaim 7 is invalid for lack of novelty over CN 830, as bayonet coupling of second lid (pressure cooker lid) to housing in a pressure cooking mode is inherently present
RespondentLegal basis: Art. 54 EPCClaim 8 is invalid for lack of novelty over CN 830, which clearly discloses a pressure cooker with a pot cover and bayonet coupling, constituting a pressure cooking lid
RespondentLegal basis: Art. 54 EPCSHARKNINJA is the unsuccessful party for both EP 198 (dismissed) and EP 201 (withdrawn) and must bear SEB's legal costs
RespondentLegal basis: Art. 69(1) and (3) UPCA; R. 150(2) RoPInterim costs award is capped at 50% of the ceiling of recoverable costs (EUR 300,000 for entire case), with EP 201 portion set at EUR 120,000 given no oral hearing was held for that part
RespondentLegal basis: Art. 69 UPCA; R. 211.1(d) RoP; R. 152.2 RoP; CoA Meril v. Edwards, 25 November 2025
Rejected arguments
What the court did not agree with — and why.
CN 830 does not disclose a fan/air movement device because the device is a lightwave oven, not an air fryer, and microwave/lightwave ovens do not use fans to direct air onto food
ClaimantLegal basis: Art. 54 EPCThe electric motor visible in CN 830 Fig. 2 could be driving only a cooling fan, not an air-circulation fan
ClaimantLegal basis: Art. 54 EPCThe fallback combination of Claims 1 and 8 should be considered as an alternative basis for the provisional measures request
ClaimantLegal basis: R. 263.3 RoP; CoA UPC_CoA_898/2025 Onward v. Niche'To couple' in Claim 1 encompasses indirect coupling of the second lid via an intermediate component, not only direct coupling by the lid's own fixing means
ClaimantLegal basis: Art. 69 EPC; Protocol on Interpretation of Art. 69 EPC