UPC_CFI_660/2024

CYBERANALYSIS WORKFLOW ACCELERATION

InfringementMain Infringement ActionMannheim LDInfringementCase Closed

Overview Decisions Reasoning Citations Documents Timeline

Coverage: Partial.Reasoning extracted with partial coverage — some sections may be incomplete.

Plain-English summary

Centripetal Limited sued Palo Alto Networks for infringement of EP 3 652 914 B1 (cyberanalysis workflow acceleration using machine-learning-based event log triage) for the German and French parts. Palo Alto Networks counterclaimed for revocation; the Mannheim Local Division revoked the patent in full for both territories, finding all 12 claim amendment groups and the unconditionally amended main request lacked inventive step over prior art (principally HLCC17 on n-gram/polygram analysis of domain names), and accordingly dismissed the infringement action.

Accepted arguments

What the court agreed with — by party.

Claims of EP 3 652 914 (including unconditionally amended main request and all auxiliary requests) lack inventive step over prior art
RespondentLegal basis: Art. 56 EPC; problem-solution approach; inventive step
Note: Mannheim Local Division accepted Palo Alto Networks' revocation counterclaim, finding all claim versions (including 12 amendment groups) lacked an inventive step over the prior art, in particular HLCC17 and related references.
N-gram/polygram probability distribution concept from prior art (HLCC17) renders claim features relating to reportability likelihood determination obvious
RespondentLegal basis: Art. 56 EPC; obviousness
Note: Court held that applying n-gram vectors to domain names generally renders features requiring such analysis for the leading label of the effective 2nd-level domain of a FQDN obvious; the concept was not limited to file paths.

Rejected arguments

What the court did not agree with — and why.

Unconditionally amended main request and auxiliary requests 1–12 should be maintained
ClaimantLegal basis: Art. 56 EPC
Reason: Each claim amendment was found to lack inventive step over the prior art (primarily HLCC17); the combination of all features in amendment 12 similarly provided no inventive step.
HLCC17 only discloses n-gram vectors applied to URL filepaths, not domain names generally
ClaimantLegal basis: Art. 56 EPC
Reason: Court found HLCC17 discloses the n-gram concept for domain names generally, not limited to filepaths; even if limited to filepaths, applying it to other URL components including second-level domains would not involve an inventive step.

Key legal principles

Doctrines and rules cited in the reasoning.

All claim amendments evaluated for inventive step; no 'safe harbour' in amendment merely by adding features already disclosed in prior art Generalisation of a prior-art concept from one technical sub-domain to a related one does not involve an inventive step Revocation of patent defeats infringement action regardless of infringement merits

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Prior art relied on

References cited and the role they played.

HLCC17Obviousness combination

Claim construction notes

The court construed claim features relating to 'reportability likelihood' determination and the use of polygram (n-gram) probability distributions applied to the leading label of the effective second-level domain of a fully qualified domain name. Claim amendment 10's feature CA10-1.4.2.2.1.2 does not preclude further entropy values being used, but the second-level domain feature was rendered obvious by HLCC17's general teaching on domain name analysis.