On October 14, 2025, the Seventh Civil Division of Munich Regional Court ruled in favor of ZTE Corporation's application for an Anti-Anti-Suit Injunction (AASI). This injunction targets a complaint filed and pursued by Samsung with the European Telecommunications Standards Institute (ETSI) – a complaint aimed at excluding ZTE from future standardization work. Pursuant to the court's order, Samsung must immediately withdraw this complaint.

Notably, Samsung had attempted to rely on the findings of fact regarding provisional licenses from the High Court of England and Wales within the ETSI proceedings. However, on October 13, 2025, the Court of Appeal of England and Wales formally granted ZTE's appeal concerning provisional licenses, which will now proceed under an expedited hearing schedule.

Recent developments in anti-injunction regimes have seen significant progress: the Unified Patent Court and Munich Regional Court have expanded the scope of this legal tool through “anti-interim injunction” rulings, sparking jurisdictional tensions between different legal jurisdictions. The standard-essential patent dispute between ZTE and Samsung exemplifies this context. Although the High Court of England and Wales ruled that Samsung was entitled to a provisional license, ZTE promptly appealed, preventing Samsung from actually obtaining the license to date. Furthermore, parallel litigation initiated by Samsung in the United States has also failed to achieve substantive progress.

Notably, the injunction issued by the Munich court was granted through ex parte proceedings—meaning it was issued without notifying the opposing party or holding a hearing. Therefore, Samsung may still legally request a hearing and file an appeal. Given that the ETSI General Assembly is scheduled for early December, this case carries particular urgency.

The case is being heard by the Seventh Civil Division of Munich Regional Court No. 1. The panel consists of Presiding Judge Dr. Oliver Schoen, Judge Dr. Schweyer, and Judge Tözsér.