Cases
Workhorse listing across all UPC cases. Filters apply across tabs.
| Date | Case | Division | Action | Motion | Outcome | Summary |
|---|---|---|---|---|---|---|
| 2025-07-03 | UPC_APP_25616/2025 | Court of Appeal | Application Rop 265 | Procedural | Withdrawn | The Court of Appeal ruled on Advanced Bionics' withdrawal of two appeals, holding that separate court fees are required for appeals against revocation decisions and counterclaim for revocation decisions even when issued in a single document by the Court of First Instance. |
| 2025-07-03 | UPC_APP_23563/2025 | Court of Appeal | Application Rop 265 | Procedural | Withdrawn | The Court of Appeal allowed the withdrawal of an appeal by the anonymous appellant against the Brussels Local Division's decision dismissing infringement claims against OrthoApnea S.L. and Vivisol B BV concerning EP 2 331 036, ordered the appellant to bear OrthoApnea's appeal costs, and referred the quantum of costs to a separate costs procedure. |
| 2025-07-03 | UPC_APP_2947/2025 | Munich LD | Generic application | Procedural | Procedural only | The Munich Local Division ordered Flextronics International Europe B.V. (defendant in a Headwater Research infringement action concerning EP3110069) to provide security for costs covering both its role as defendant in the infringement action and as counterclaimant in the revocation counterclaim, following guidance from the UPC Court of Appeal. |
| 2025-07-03 | UPC_APP_47247/2024 | Munich LD | Generic application | Costs | Procedural only | The Local Division Munich ordered Headwater Research to provide security for costs covering both the infringement action and the revocation counterclaim proceedings, holding that a defendant compelled to file a revocation counterclaim to preserve its invalidity defence may also obtain security for those counterclaim costs under Art. 69(4) UPCA and R.158.1 RoP. |
| 2025-07-03 | UPC_APP_32024/2025 | Munich LD | Generic application | Procedural | Dismissed | Munich Local Division (3 July 2025) dismissed Lenovo's application for an extension of time, holding that the application lacked any legal interest because the UPC case management system's scheduled downtime was already automatically covered by R. 301.2 RoP's automatic extension provision. |
| 2025-07-03 | APL_8639/2025 | Court of Appeal | Application to leave to appeal a cost decision (RoP221) | Costs | Costs only | The Court of Appeal dismissed Tiroler Rohre GmbH's appeal against the first-instance costs decision following withdrawal of the infringement action, confirming the general applicability of R. 150 ff. RoP for cost assessment proceedings after withdrawal under R. 265 RoP. The court confirmed that cost assessment after action withdrawal follows the standard R. 150 ff. procedure and that the appeal review is marginal (limited to whether the awarded amount is unreasonable or contrary to Art. 69(1) UPCA). The costs award of EUR 84,033.76 to SSAB was upheld. |
| 2025-07-03 | UPC_APP_28457/2025 | Munich LD | Generic application | motionName.jurisdictional | Procedural only | The President of the Court of First Instance granted Renault's application to change the language of the proceedings from German to English (the language of the patent) in the Munich Local Division infringement proceedings concerning vehicular electronics. The court found that the balance of interests favoured English, as both parties were comparable in size and resources, English was the language of the relevant technology, and the change would not cause delays. |
| 2025-07-03 | UPC_CoA — (related to Tandem Diabetes appeal) | Court of Appeal | Generic application | — | Procedural only | The Court of Appeal ordered reimbursement of 60% of the appeal court fees paid by Tandem Diabetes Care Europe B.V. and Tandem Diabetes Care, Inc. following settlement of the appeal before closure of the written procedure, pursuant to Rule 370.9(c)(i) and Rule 370.11 RoP. |
| 2025-07-03 | UPC_CoA_221/2025 | Court of Appeal | Appeal RoP220.2 | — | Procedural only | The Court of Appeal ruled on the number of US attorneys permitted to access confidential information in infringement proceedings by NST against Qualcomm. The court ordered that only one trusted US attorney (rather than multiple as NST requested) be granted access to confidential information, balancing NST's right to an effective remedy against Qualcomm's legitimate expectation of adequate confidentiality protection. |
| 2025-07-03 | UPC_CoA_153/2025 | Court of Appeal | Application to leave to appeal a cost decision (RoP221) | — | Costs only | The Court of Appeal dismissed Tiroler Rohre's appeal against the Munich Local Division's cost order following withdrawal of its application for provisional measures. The Court held that the ordinary cost rules (R. 150 et seq. RoP) apply to cost decisions following withdrawal under R. 265 RoP; no special rule applies requiring reference to the panel rather than the standing judge. The legal review on appeal is limited to a marginal review of whether costs awarded are reasonable and proportionate (Art. 69(1) UPCA). The judge-rapporteur's detailed cost assessment showed no such deviation. |
| 2025-07-02 | ORD_29159/2025 | Dusseldorf LD | Generic Order | Procedural | Procedural only | The Düsseldorf Local Division issued a procedural order pursuant to Art. 33(3)(a) UPCA, deciding to retain both the infringement action and the counterclaim for revocation together, and requesting assignment of a technically qualified judge. |
| 2025-07-02 | UPC_APP_31707/2025 | Mannheim LD | Generic application | Procedural | Procedural only | The Mannheim Local Division issued a procedural order in the Corning v Hisense/TCL/LG Electronics infringement action concerning EP3296274, granting a time limit extension for the defendants to file their statements of defence. |
| 2025-07-02 | UPC_APP_28415/2025 | Munich LD | Generic application | Procedural | Procedural only | Procedural order on a security-for-costs application by claimant SWARCO FUTURIT against intervener Shenzhen Dianming Technology Co., Ltd. The court addressed whether an admitted intervener is subject to security-for-costs obligations under R. 158 RoP. Intervener's primary request to reject the security application was considered; a separate ruling on the merits of the security application was issued. |
| 2025-07-01 | ORD_31755/2025 | Court of Appeal | Generic Order | Procedural | Procedural only | Order from the Court of Appeal (UPC_CoA_542/2025 and UPC_CoA_526/2025) staying appeal proceedings concerning security for costs in full, following the insolvency of the Easee companies. Both Easee and Visibly had cross-appealed the Hamburg Local Division's order requiring EUR 75,000 security for the revocation action. The Court of Appeal stayed both appeals pursuant to R. 295m RoP due to insolvency proceedings regarding the Easee companies. |
| 2025-06-30 | UPC_APP_29093/2025 | Dusseldorf LD | Generic application | Procedural | Procedural only | Procedural order from Düsseldorf Local Division in infringement proceedings concerning EP 1 970 677. Claimants are F. Hoffmann-La Roche AG and Roche Diabetes Care GmbH; defendants include Tandem Diabetes Care entities, VitalAire GmbH, Dinno Santé, Air Liquide Healthcare Nederland, and Rubin Medical ApS. The order addresses a procedural matter (likely scheduling or written procedure), with no substantive ruling on infringement or validity. |
| 2025-06-30 | UPC_APP_26306/2025 | Paris CD | Application RoP262.1 (b) | Procedural | Procedural only | The Paris Central Division issued a procedural order on public access to the register under R.262.2(b) RoP in infringement proceedings concerning EP2661892 (Nokia v HP Printing). The court addressed whether written pleadings and evidence should be accessible to a third-party applicant (Bardehle Pagenberg) while balancing the integrity of pending proceedings. |
| 2025-06-30 | UPC_APP_19984/2025 | Paris CD | Application RoP262.1 (b) | Procedural | Procedural only | Paris Central Division procedural order on Acer's application for public access to written pleadings and evidence in revocation proceedings (HP Printing/Computing Solutions vs Nokia Technologies, EP 2 661 892). The court addressed the conditions under which third-party access to court documents may be excluded for reasons of integrity of other proceedings, and whether access once granted carries any confidentiality obligation. Leave to appeal granted. |
| 2025-06-30 | UPC_CFI_181/2024 | Paris CD | Application RoP262.1 (b) | — | Procedural only | Procedural order from the Paris Central Division (Seat) dated 30 June 2025 granting Acer Computer GmbH's application under R. 262.1(b) RoP for public access to written pleadings and evidence filed in proceedings concerning an application to amend patent EP 2 661 892 B1 (Nokia Technologies Oy vs HP Printing). The court found Acer had a specific interest in the validity of the patent given that Nokia had brought an infringement action against Acer based on the same patent. Access was granted without ongoing confidentiality obligations post-access. |
| 2025-06-30 | UPC_CFI_181/2024 | Paris CD | Application RoP262.1 (b) | — | Procedural only | Procedural order granting Bardehle Pagenberg Partnerschaft mbB (a third-party applicant) access to written pleadings and evidence filed in the proceedings, subject to a confidentiality obligation while proceedings are pending. The court held that public access may be granted before proceedings end and the court may impose conditions to protect the integrity of proceedings. |
| 2025-06-27 | ACT_67704/2024 | Munich CD | Revocation Action | Procedural | Procedural only | Procedural order of Munich Central Division (27 June 2025) in a revocation action concerning EP 4 019 790, scheduling an online interim conference via Cisco Webex for case management purposes and setting submission deadlines. |
| 2025-06-27 | UPC_APP_24524/2025 | Munich LD | Application Rop 333 | Procedural | Procedural only | Procedural order from the Munich Local Division (UPC_CFI_148/2024 and UPC_CFI_503/2024) on Zentiva's application under R. 333 RoP for panel review of the judge-rapporteur's case management order of 8 May 2025 in Sanofi's infringement action concerning EP 2 493 466. The full panel reviewed how preliminary objections should be handled and the timetable for subsequent proceedings. |
| 2025-06-27 | UPC_APP_28345/2025 | Mannheim LD | Generic application | Procedural | Procedural only | Mannheim Local Division order (judge-rapporteur Böttcher) in infringement proceedings by Irdeto B.V. against DJI entities (SZ DJI Technology, DJI Europe B.V., DJI GmbH) and Solectric GmbH concerning EP 2 831 787. DJI Europe, DJI GmbH, and Solectric requested harmonisation and extension of the statement of defence deadline to 15 September 2025; Irdeto objected. The order likely grants a harmonised extension, given the unresolved service on Defendant 1 (China) and the reasonable case management arguments. No substantive ruling. |
| 2025-06-27 | UPC_APP_29553/2025 | Mannheim LD | Generic application | Procedural | Procedural only | Procedural order by the Mannheim Local Division judge-rapporteur granting Palo Alto Networks (defendant) a two-week extension of the deadline for its rejoinder and related filings in patent infringement proceedings brought by Centripetal Ltd. The extension was justified by the exceptional circumstance that the defendant's key technical support employee was resident in Israel and could not safely return due to flight restrictions resulting from the outbreak of hostilities in the region. |
| 2025-06-26 | UPC_APP_26135/2025 | Hamburg LD | Generic application | Procedural | Procedural only | The Hamburg Local Division granted a stay of proceedings under Rule 311 RoP following the bankruptcy of defendants Easee B.V. and Easee Holding B.V., suspended the security for costs obligation for all defendants during the stay, and held that the court's power to revoke the security order was suspended pending an appeal. |
| 2025-06-26 | APL_36389/2024 | Court of Appeal | Appeal RoP220.1 | motionName.appeal_decision | Dismissed | Court of Appeal (26 June 2025) rejected Ballinno's appeal against (1) the security for costs order of EUR 56,000, and (2) the CFI's cost order. As Ballinno had withdrawn its requests for provisional measures on appeal, the action was declared devoid of purpose and disposed of under R. 360 RoP. Ballinno was ordered to bear the Kinexon companies' and UEFA's legal costs for the appeal proceedings. Value of dispute set at EUR 100,000. |
| 2025-06-26 | UPC_APP_28639/2025 | Court of Appeal | Application Rop 223 | Procedural | Procedural only | The Court of Appeal (Panel 2: Kalden, Rombach, Simonsson) granted suspensive effect to the managing director's appeal and provisionally granted suspensive effect to the Easee companies' appeal pending clarification of their representation authority (following insolvency), against the Hamburg Local Division's order requiring Easee to provide security for legal costs of EUR 75,000 for the revocation counterclaim proceedings. The court found the managing director's arguments on the impermissibility of security for costs for defendants in revocation proceedings raised an obvious legal error. |
| 2025-06-25 | ORD_17811/2025 | Milan CD | Decision By Default | Default judgment | Permanent injunction | The Milan Central Division issued a decision by default against Spiridonakis Bros GP (Greece) in favour of Maschio Gaspardo S.p.A. (Italy) concerning EP 1 998 604 (agricultural reversible subsoiler tools). The defendant failed to enter proceedings. The Court found that the 'Bellota tool' sold by Spiridonakis constituted infringement of claims 1, 2, 3, 5, 6, 9 and 10 of the patent. The Court issued a permanent injunction against further infringement in Italy, Germany, France, Romania and Bulgaria with a EUR 500 per-set penalty, ordered disclosure of distribution chain information (EUR 100/day penalty for non-compliance), and awarded EUR 25,000 for legal costs plus reimbursement of court fees. The Court applied the 'double territoriality' requirement of Art. 26 UPCA, finding that an offer and the act of putting into effect need not occur in the same Contracting Member State for bundle patents. |
| 2025-06-23 | UPC_APP_22747/2025 | Court of Appeal | Application Rop 365 | Procedural | Settled | The Court of Appeal confirmed the settlement agreement between Plant-e Knowledge B.V./Plant-e B.V. and Arkyne Technologies S.L. in both the infringement appeal and the counterclaim for revocation appeal, declared the proceedings closed, and ordered reimbursement of 60% of court fees to Arkyne. |
| 2025-06-23 | ORD_29757/2025 | Dusseldorf LD | Generic Order | Procedural | Procedural only | Procedural order of Düsseldorf Local Division (23 June 2025) providing preliminary guidance on the claim feature breakdown for EP 2 892 442 in preparation for the oral hearing of 1 July 2025 in an infringement action brought by Aesculap AG against Shanghai International Holding Corporation GmbH. |
| 2025-06-23 | APL_14947/2025 | Court of Appeal | Appeal RoP220.2 | motionName.appeal_decision | Dismissed | Court of Appeal (Panel with President Grabinski) dismissed Sumi Agro Limited and Sumi Agro Europe Limited's appeal against a Munich Local Division order that had refused to revoke provisional measures granted to Syngenta Limited concerning EP 2 152 073 (a crop protection patent). The appeal concerned the timing of payment of court fees: the Court of Appeal held that fees are considered paid on time when a bank transfer order is given at the time of filing, not when the bank account actually receives the funds. On the merits, the court confirmed the first-instance cost decision. Sumi Agro was ordered to bear the costs of the appeal. |
| 2025-06-20 | UPC_APP_28294/2024 | Munich LD | Preliminary objection | motionName.jurisdictional | Dismissed | The Munich Local Division rejected Motorola's preliminary objection to jurisdiction, holding that the court had jurisdiction under Art. 33(1)(a) UPCA based on alleged infringing acts in Germany, and allowed proceedings to continue. |
| 2025-06-20 | UPC_APP_61580/2024 | Munich LD | Preliminary objection | motionName.jurisdictional | Dismissed | Preliminary objection by Motorola Mobility LLC, Motorola International Sales LLC, Motorola Mobility Germany GmbH and Flextronics International Europe B.V. challenging jurisdiction of Munich Local Division was rejected in Headwater Research LLC v. Motorola entities (EP 3 110 069). The court held: (1) Art. 33(1)(a) UPCA jurisdiction is established by the claimant's credible assertion of infringement in Germany, including delivery of devices; (2) Art. 33(1)(b) sentence 2 UPCA does not narrow the rule for multiple defendants where each infringes in Germany or has seat there; (3) Flextronics as logistics provider for Motorola was plausibly alleged to have participated in infringement, supporting Munich jurisdiction. Appeal not allowed. |
| 2025-06-20 | UPC_APP_22313/2025 | Milan LD | Application Rop 333 | Procedural | Procedural only | Milan Local Division panel dismissed Ericsson's application for review (Rule 333 RoP) of the judge-rapporteur's order refusing to impose an 'external eyes only' confidentiality regime for license agreements submitted as FRAND evidence. The panel held that Ericsson failed to substantiate the specific antitrust risk from allowing one Asustek employee access to the documents. Leave to appeal was granted to allow the Court of Appeal to set a standard on external-eyes-only confidentiality regimes in SEP/FRAND cases. |
| 2025-06-20 | UPC_APP_30222/2024 | Munich LD | Preliminary objection | motionName.jurisdictional | Procedural only | Munich Local Division dismissed preliminary objections to jurisdiction filed by Motorola Mobility LLC and related entities against Headwater Research LLC's infringement action (UPC_CFI_149/2024). The court upheld jurisdiction under Art. 33(1)(a) UPCA for defendants that committed infringing acts in Germany and are domiciled there, and also upheld jurisdiction under Art. 33(1)(b) UPCA (with a narrower interpretation) over the remaining defendants including Digital River Ireland Ltd. Leave to appeal was not granted. |
| 2025-06-20 | UPC_CoA_393/2025 | Court of Appeal | Appeal RoP220.2 | — | Dismissed | The Court of Appeal allowed AorticLab's appeal and set aside the Munich Local Division's order granting Emboline's application for security for costs. The CoA held that Art. 69(4) UPCA provides no legal basis for a security for costs at the request of the claimant in an infringement action in response to a defendant's counterclaim for revocation. Allowing such security would unreasonably restrict the defendant's right to raise an invalidity defence by means of a mandatory counterclaim. |
| 2025-06-19 | UPC_APP_8339/2025 | Court of Appeal | Generic application | motionName.appeal_decision | Procedural only | The Court of Appeal set out general principles for rehearing applications under Art. 81(1)(b) UPCA, establishing that only fundamental procedural defects that would have led to a different outcome can justify rehearing, in proceedings where Alexion sought to reopen a dismissed provisional measures appeal against Amgen concerning EP 3 167 888. |
| 2025-06-19 | UPC_APP_25965/2025 | Court of Appeal | Application Rop 360 | Procedural | Settled | Procedural order by the Court of Appeal (UPC_CoA_170/2025, 18 June 2025) closing the appeal proceedings following an out-of-court settlement between ILME and PHOENIX CONTACT. The parties had settled before the CoA issued a substantive decision on ILME's appeal against dismissal of its preliminary objection. The main infringement action at first instance had already been withdrawn. No costs were claimed by either party. |
| 2025-06-19 | UPC_APP_8340/2025 | Court of Appeal | Generic application | motionName.appeal_decision | Dismissed | Court of Appeal Panel 2 rejected Alexion Pharmaceuticals' application for rehearing (R. 245 RoP) of the earlier Court of Appeal order dismissing Alexion's appeal against the Hamburg Local Division's denial of provisional measures. Alexion had alleged fundamental procedural defects (new claim interpretation standard applied without being heard, and incorrect facts). The Court held that no fundamental procedural defect within the meaning of Art. 81(1)(b) UPCA / R. 247(c) RoP was established. Alexion ordered to bear Samsung's costs of the rehearing proceedings. |
| 2025-06-19 | UPC_CFI_363/2024 | Paris LD | Generic application | — | Procedural only | Procedural order from the Paris Local Division dated 19 June 2025 dealing with security for costs requested by defendant GISELA MAYER GmbH against claimant N.J DIFFUSION SARL in an infringement action. NJ Diffusion had been placed in judicial reorganization (redressement judiciaire) on 5 June 2025. The court had to deal with: (1) the intervention of the court-appointed administrator and judicial representative; (2) request to provide security for costs under R. 158 RoP; and (3) the oral hearing scheduled for 20 June 2025. The order addresses the effect of insolvency proceedings on pending UPC proceedings under R. 311 RoP. |
| 2025-06-18 | UPC_APP_28226/2025 | Dusseldorf LD | Application RoP262A | Procedural | Procedural only | Procedural order from the Düsseldorf Local Division (UPC_CFI_504/2023) on Roche's application for confidentiality protection under R. 262A RoP in proceedings against Tandem Diabetes Care and others concerning EP 1 970 677. The order addressed composition of the confidential club and access rights for multiple defendants and their representatives. |
| 2025-06-18 | UPC_APP_22462/2025 | Dusseldorf LD | Generic application | motionName.jurisdictional | Procedural only | President of the UPC Court of First Instance granted The Walt Disney Company (Benelux) B.V.'s application to change the language of proceedings to English (the patent grant language) in proceedings before the Düsseldorf Local Division, applying the same reasoning as in two prior orders of April/May 2025 in related cases. The order was not conditional on specific translation arrangements. |
| 2025-06-17 | UPC_APP_27069/2025 | Court of Appeal | Generic application | Procedural | Procedural only | The Court of Appeal declared inadmissible Knaus Tabbert AG's 'Gegenvorstellung' (objection to the rejection of its stay application under R. 223 RoP), holding that a mere challenge to the reasoning of the appellate order denying a suspensive effect does not constitute an admissible procedural remedy, and that new facts about third parties' financial situation that could have been raised at first instance are not admissible. |
| 2025-06-17 | UPC_APP_27069/2025 | Court of Appeal | Generic application | Procedural | Dismissed | The Court of Appeal (Panel 2) declared inadmissible Knaus Tabbert AG's 'Gegenvorstellung' (objection) filed against the Court of Appeal's earlier rejection of Knaus Tabbert's application for suspensive effect (R.223 RoP). The Court held that an objection which merely challenges the Court of Appeal's legal opinion expressed in the order rejecting a suspensive effect application is inadmissible. The infringement action by Yellow Sphere Innovations GmbH and Erwin Härtwich regarding EP 3 356 109 (vehicle frame with foam resin structural part) continues. |
| 2025-06-17 | ACT_20004/2024 | Milan LD | Infringement Action | Procedural | Procedural only | The Milan Local Division issued a post-interim-conference order in infringement proceedings between Progress Maschinen & Automation AG and SCHNELL/AWM, deciding on the admissibility of a new auxiliary request, withdrawing certain evidence production requests, and setting the case for oral hearing. |
| 2025-06-17 | ACT_20004/2024 | Milan LD | Infringement Action | Procedural | Procedural only | The Milan Local Division issued a post-interim-conference procedural order in the Progress Maschinen v. AWM/Schnell infringement action, setting the oral hearing schedule and deferring to the panel the admissibility of a new auxiliary patent amendment request. |
| 2025-06-16 | UPC_APP_28386/2025 | Munich LD | Generic application | Procedural | Procedural only | Munich Local Division (16 June 2025) stayed the infringement and revocation proceedings concerning EP 3 742 231 by consent of all parties (R. 295(d) RoP) until three months after the next EPO Board of Appeal oral hearing in T0187/24, to allow settlement negotiations. The oral hearing scheduled for 7 October 2025 was cancelled. |
| 2025-06-16 | ACT_14764/2025 | Hamburg LD | Application for provisional measures | Preliminary injunction | PI granted | Hamburg Local Division granted a preliminary injunction ordering OTEC Präzisionsfinish GmbH to cease and desist from manufacturing, offering, placing on the market, using, exporting, or possessing in 18 UPC contracting states an electrolytic medium for electropolishing processes that infringes a patent for such a medium. The court held that validity is established on a balance of probabilities standard (more likely than not valid); the burden for invalidity lies with the defendant. The weighing of interests favoured the applicant as the defendant's product enabled new machine sales creating market opportunities lost to the applicant. The defendant's request for security for enforcement was denied as no sufficient facts (e.g. financial difficulties) were presented. Penalty of up to EUR 250,000 per non-compliance. |
| 2025-06-16 | ACT_14764/2025 | Hamburg LD | Application for provisional measures | Procedural | Procedural only | The Hamburg Local Division (full panel: Klepsch, Schilling, Rinkinen, Goedeweeck) partially granted OTEC Präzisionsfinish GmbH's application for rectification (R. 353 RoP) of the provisional measures order of 16 June 2025 granted to Steros GPA Innovative S.L. concerning EP 4 249 647. The court corrected clerical mistakes (omitted letters) and certain erroneous references (water-in-oil to oil-in-water emulsion, a missing table reference, and a result table entry). However, the court rejected OTEC's request to alter the description of the 'skilled person' in the art, finding that this went beyond rectification of obvious slips. |
| 2025-06-16 | UPC_CFI_140/2024 | Dusseldorf LD | Infringement Action | — | Infringed | Decision of the Düsseldorf Local Division finding that Curio Bioscience infringes EP 2 697 391 B1 owned by 10x Genomics. The court ordered: (A) cessation of the infringing acts in UPC member states; (B) recall from distribution channels; (C) permanent removal from distribution channels; (D) rendering of accounts; (E) damages for acts after 30 November 2019; (F) periodic penalty payments of up to EUR 100,000 per day. The action was dismissed in other respects. Costs: borne 30% by claimant, 70% by defendant. Value in dispute set at EUR 3,000,000; ceiling for recoverable representation costs EUR 400,000. |
| 2025-06-15 | UPC_CFI_26/2024 | Dusseldorf LD | Infringement Action | Procedural | Procedural only | Düsseldorf Local Division dismissed Samsung's application for security for costs against Headwater Research LLC under R. 158 RoP. The Court found that while enforcing a cost order against a US-domiciled entity might be more burdensome, the evidence showed Headwater generates recurring revenues from licensing, making the concern about non-recovery insufficiently justified. |