The Unified Patent Court (UPC) Hamburg Local Division issued a preliminary injunction on April 7, 2026, against several Dreame Group entities regarding the “Dazzle Hair Styler.” According to the court documents (UPC_CFI_2255/2025), the ruling confirms the UPC’s broad jurisdiction over defendants domiciled in UPC member states, while simultaneously clarifying the limits of “anchor defendant” jurisdiction when involving UK-based distributors and EU regulatory representatives.
How does the UPC establish international jurisdiction?
The Hamburg Local Division affirmed that the UPC possesses international jurisdiction over defendants domiciled within any UPC contracting member state under Article 4 of the Brussels I Recast Regulation. In this case, the court applied this to Swedish, German, and Dutch defendants. For non-UPC entities, such as the Hong Kong-based Dreame HK, jurisdiction was established under Article 7(2) of the same regulation, as the company operated websites targeting the UPC territory, making it the place where the harm occurred.
The court adopted a broader, functional approach to claim construction. It ruled that a “slot formed by an overlap of a first end of the wall and a second end of the wall” is not strictly limited to separate plates, but includes overlapping apertures in a tubular wall, provided they achieve the same technical effect.
Why did the attempt to anchor UK jurisdiction fail?
Dyson sought to use Dreame NL as an “anchor defendant” to establish jurisdiction over Cellcom, a UK-based exclusive distributor. The Hamburg Local Division rejected this, ruling that the appointment of an authorized representative for regulatory purposes under the UK-EU Windsor Framework does not create a sufficient connection to the UK market to anchor jurisdiction. The court noted these regulations were intended to facilitate exports from Northern Ireland to the Republic of Ireland, rather than setting a product safety level for the UK. Consequently, the UPC did not have jurisdiction over the UK distributor for these specific acts.
What constitutes “imminent” infringement in UPC courts?
The court demonstrated a willingness to grant injunctive relief even before a product officially hits the shelves. Regarding the defendant Teqphone, evidence from a test purchase attempt—where a staff member stated the Dazzle would be available in-store within two to three months—was deemed sufficient proof of imminent infringement. The court held that because preparations were fully completed, the legal threshold for an injunction was met.
Frequently Asked Questions
- What is the “Coanda effect” mentioned in the case?
It is the aerodynamic phenomenon where air emitted from a slot in the styling attachment is attracted to the external surface of the wall, causing hair to wrap automatically around the device without manual winding. - Does the UPC have jurisdiction in Spain?
Yes, the court confirmed jurisdiction over Dreame NL for infringing acts in Spain based on its UPC domicile. Furthermore, Dreame HK was included as a co-defendant because it jointly operated the Spanish website with Dreame NL. - How does this affect future patent litigation?
This ruling serves as a precedent that while the UPC has wide-reaching power, it is actively refining its “long-arm” jurisdiction. Future cases will likely rely on the CJEU’s upcoming guidance regarding whether an EU authorized representative can be a sufficient link for non-EU defendants.
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