On February 25, 2025, the Court of Justice of the European Union (CJEU) issued a far-reaching ruling in a complex patent dispute case between BSH Hausgeräte GmbH (BSH) and Swedish home appliance giant Electrolux. The core of this dispute lies in whether the courts of EU member states have jurisdiction over infringement actions involving European patents granted in another member state but not validated in the former.
The background of the case is as follows: BSH holds a patent granted in an EU member state and alleges that a product sold by Electrolux in another member state infringes upon its patent rights. Electrolux contests this, arguing that since the patent has not been validated in the member state where its product is sold, the local courts do not have jurisdiction to hear the case. Electrolux further challenges the validity of the patent as a defense.
After carefully reviewing relevant regulations and precedents, the CJEU issued a historic ruling. The court held that, pursuant to Article 24(4) of the Brussels Ibis Regulation, EU member state courts do have jurisdiction to hear infringement actions involving European patents not validated in their respective countries, provided certain conditions are met. This provision aims to ensure that patent infringement actions can be handled uniformly and effectively within the EU, avoiding confusion over jurisdiction due to differing patent validation procedures.
However, the court also made it clear that, while member state courts have jurisdiction to hear infringement actions, they do not have exclusive jurisdiction over the validity of patents. This means that if the defendant challenges the validity of a patent, such challenges should be heard by the courts of the member state where the patent was granted or by the European Patent Office. This ruling protects the legitimate rights and interests of patent holders while avoiding the complication of litigation procedures due to patent validity disputes.
This ruling has had a profound impact on the patent dispute resolution mechanism within the EU. It clarifies the jurisdiction of member state courts in handling infringement actions involving European patents not validated in their countries, providing a clearer and more predictable legal environment for patent holders and alleged infringers. At the same time, the ruling emphasizes the principle that patent validity disputes should be heard by specialized bodies, contributing to the stability and authority of the patent system.
With the development of globalization and digitization, patent disputes are increasingly common among multinational corporations. This ruling by the CJEU not only provides clear guidance for patent dispute resolution within the EU but also offers useful insights for patent dispute resolution globally. It reminds us that when dealing with patent disputes, we should fully consider legal differences and procedural provisions across different countries and regions to ensure the fairness and effectiveness of litigation.
