ARTICLE
2 June 2026

LD Düsseldorf, May 27, 2026, Decision In The Infringement Action And Counterclaim For Revocation, UPC_CFI_807/2024, UPC_CFI_334/2025

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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 four-step equivalence test applied by LD The Hague forms a coherent whole suitable for examining patent infringement by equivalence.
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1. Key takeaways

The four-step equivalence test applied by LD The Hague forms a coherent whole suitable for examining patent infringement by equivalence.

1. Technical equivalence

Does the variation solve (essentially) the same problem that the patented invention solves and performs (essentially) the same function in this context?

2. Fair protection for the patentee

Is extending the protection of the claim to the equivalent proportionate to a fair protection for the patentee: in view of his contribution to the art and taking into account the question whether it is obvious to the skilled person from the patent publication how to apply the equivalent element (at the time of infringement)?

3. Reasonable legal certainty for third parties

Does the skilled person understand from the patent that the scope of the invention is broader than what is claimed literally? Is there, in the eyes of the skilled person, a good reason to limit the scope of protection of the claim to a device/method as claimed literally?

4. Is the allegedly infringing product novel and inventive over the prior art? (i.e. no successful Gillette/Formstein defence)

Technical equivalence

Technical equivalence requires demonstrating each substituted feature’s specific function in achieving the objective of the patent and explaining why the variation essentially performs the same function, not merely arguing that the patent’s objective task is met.

Obviousness

A complete redesign of the claimed device generally negates obviousness of applying the equivalent element for the skilled person.

2. Division

LD Düsseldorf

3. UPC number

UPC_CFI_807/2024 UPC_CFI_334/2025

4. Type of proceedings

Infringement action, counterclaim for revocation

5. Parties

Claimant: Wonderland Nurserygoods Co., Ltd.

Defendants: Cybex GmbH, Cybex Retail GmbH, Columbus Trading-Partners GmbH & Co. KG

6. Patent(s)

EP 1 905 615

7. Body of legislation / Rules

Art. 69 EPC, Art. 54(1) EPC, Art. 56 EPC, Art. 123(2) EPC, Art. 138(1)(c) EPC, Art. 32(1) UPCA.

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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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