ARTICLE
9 September 2026

Court Of Appeal, August 28, 2026, Decision UPC_CoA_678/2025

BP
Bardehle Pagenberg

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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 UPC Court of Appeal Luxembourg addresses critical questions about patent amendment admissibility, claim construction methodology, and jurisdictional boundaries in cross-border infringement cases. This decision clarifies the standard of review for patent amendments under Rule 30.1 RoP and establishes important precedent on burden of proof requirements when alleging infringement in non-UPCA member states like Poland.
Luxembourg Intellectual Property
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1. Key takeaways

Admissibility of patent amendments (R. 30.1 RoP)

Review is limited to whether the patentee filed an explanation on Art. 84 and 123(2),(3) EPC compliance — not whether that explanation is convincing. Convincingness is a merits question, decided at the validity stage.

Claim construction after amendment

The unamended parts of the description remain a valid explanatory aid for interpreting amended claims.

UPC jurisdiction over Poland

Confirmed under Art. 31 UPCA, even though Polish courts retain exclusive jurisdiction over the validity of the Polish patent part (Art. 24(4). Brussels Ia; CJEU BSH v Electrolux, C-339/22)

Poland infringement claim – Burden of proof for extraterritorial infringement

The party alleging infringement outside UPCA Contracting Member States (here, Poland) must prove that the alleged acts constitute infringement under the applicable national law, only website accessibility or generic sales data is insufficient. HUROM failed to prove that the alleged acts (website accessibility, Amazon delivery options) qualify as infringement under Polish law.

2. Division

Court of Appeal Luxembourg

3. UPC number

UPC_CoA_678/2025

4. Type of proceedings

Appeal proceedings against revocation

5. Parties

Appellant: Hurom Co., Ltd.

Respondents: NUC Electronics Co., Ltd., NUC Electronics Europe GmbH, WARMCOOK

6. Patent(s)

EP 3 155 936

7. Jurisdictions

Germany, France, Italy, Netherlands, Poland (extraterritorial infringement)

8. Body of legislation / Rules

R. 30.1 RoP, Art. 84 and 123(2) EPC

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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