ARTICLE
12 January 2026

Court Of Appeal, December 24, 2025, Order Concerning An Application For Leave To Appeal Against A Cost Decision, UPC-COA-0000911/2025

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Bardehle Pagenberg

Contributor

BARDEHLE PAGENBERG combines the expertise of attorneys-at-law and patent attorneys. As one of the largest IP firms in Europe, BARDEHLE PAGENBERG advises in all fields of Intellectual Property, including all procedures before the patent and trademark offices as well as litigation before the courts through all instances.
The Court of Appeal only intervenes if awarded costs are beyond "reasonable and proportionate" or deviate from principles inherent in Art. 69 (1) UPCA and R. 150 et seqq.
Germany Intellectual Property

1. Key takeaways

Appellate review of cost decisions is limited to a marginal review (Art. 69 UPCA, R. 221 RoP)

The Court of Appeal only intervenes if awarded costs are beyond “reasonable and proportionate” or deviate from principles inherent in Art. 69 (1) UPCA and R. 150 et seqq. The Court of Appeal recognizes that the first-instance judge-rapporteur is best placed to decide on costs having managed the case step by step throughout the various stages of the proceedings.

Recoverable costs must be proportionate and within the applicable ceiling (Art. 69 UPCA, R. 152.2, R. 370.6 RoP)

Proportionality is checked against the cost ceiling, determined by the action's value. Within that ceiling, the court qualitatively assesses if the costs for the successful party's activities were reasonable.

Pending rehearing applications are irrelevant for an appeal against a cost decision

The applicant's argument that pending rehearing applications in related proceedings should be considered was dismissed by the Court as “not relevant in the present case” for the cost appeal.

2. Division

Court of Appeal

3. UPC number

UPC-COA-0000911/2025 (Appeal Number)

UPC_CFI_724/2025, ACT_34440/2025 (Decision under appeal)

4. Type of proceedings

Application for leave to appeal a cost decision

5. Parties

Applicant: Suinno Mobile & AI Technologies Licensing Oy

Respondent: Microsoft Corporation

6. Patent(s)

EP 2 671 173

7. Body of legislation / Rules

Art. 69 UPCA

R. 150 RoP

R. 151 RoP

R. 152 RoP

R. 156 RoP

R. 221 RoP

R. 223 RoP

R. 370.6 RoP

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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