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Overview · Filed: Aug 5, 2024

UPC_CFI_461/2024

Floor seal device, in particular attic steps with a plastic hinge

InfringementMain Infringement ActionHamburg LDInfringementCase Closed
Plain-English summary

Dolle A/S brought an infringement action at the Hamburg Local Division against FAKRO entities for infringement of EP 2 476 814 B1 (floor seal device / attic steps with plastic hinge). The court confirmed infringement, rejected FAKRO's counterclaim for revocation (including a late-raised inventive step attack barred by front-loading rules), and confirmed the 'same invention' standard under Art. 87 EPC equates to the direct-and-unambiguous derivation standard used for added matter. Defendants were ordered to pay 90% of costs; a correction order later addressed minor typographical and structural errors in the judgment.

Accepted arguments
What the court agreed with — by party.
  • 'The same invention' standard in Art. 87 EPC corresponds to the added-matter disclosure standard (direct and unambiguous derivation)

    ClaimantLegal basis: Art. 87 EPC; UPC_CFI_115/2024 (LD Düsseldorf, 15.10.2025)

    Note: Court confirmed priority claim is valid where the skilled person can directly and unambiguously derive the claimed subject-matter from the priority document as a whole using common general knowledge.

  • FAKRO products infringe EP 2 476 814 B1 (floor seal device/attic steps) as construed

    ClaimantLegal basis: Art. 25 UPCA

    Note: Court granted injunction, recall, removal from distribution channels, and information orders confirming infringement.

  • A term mentioned only generally in a claim cannot be restricted to a specific configuration disclosed only in cited prior art without further specification in the claim

    Claimant

    Note: Court rejected FAKRO's attempt to narrow a general claim term based on how it appeared in prior art cited in the patent description.

Rejected arguments
What the court did not agree with — and why.
  • Inventive step attack based on documents already in the proceedings, raised for the first time at oral hearing

    RespondentLegal basis: UPC RoP front-loaded proceedings; R. of counterclaim filing

    Reason: All invalidity attacks must be introduced in the counterclaim for revocation; it is not permissible to raise a new lack-of-inventive-step argument based on documents already in the file for the first time at oral hearing.

  • Counterclaim for revocation: EP 2 476 814 B1 is invalid

    RespondentLegal basis: Art. 87 EPC

    Reason: Revocation counterclaim rejected; priority was valid under the direct-and-unambiguous standard; other validity attacks were either out of time or substantively unfounded.

Claim construction notes

Court held that a general term appearing in the claims of EP 2 476 814 B1 (floor seal/attic steps) cannot be narrowed to a configuration merely because the prior art cited in the patent describes it in a specific way; the claim text must contain the limiting language.