On 7 April 2026, the Hamburg Regional Division of the Unified Patent Court (UPC) issued a preliminary injunction ruling in the patent infringement dispute between Dyson Technology Limited (hereinafter “Dyson”) and Dreame (hereinafter “Dreame”): The accused “Dreame Dazzle” product constitutes patent infringement. Accordingly, the court issued a provisional injunction against Dreame’s relevant entities in the UPC member states and Spain, whilst explicitly stating that it lacks international jurisdiction over the UK.
The case centres on Dyson’s European patent EP 3 119 235, which relates to an attachment structure for a handheld hair styling device. The core of the invention lies in a specific airflow outlet design that directs airflow along the outer surface of the attachment, thereby achieving an automatic curling effect. Dyson argued that its Airwrap product was developed based on this technology, and that ZuiMi’s “Dazzle Hair Styler” and its curling attachment fell within the scope of protection of claims 1 and 11 of the patent in question, constituting direct or equivalent infringement.
In its reasoning, the court addressed the phrase “the air outlet slot formed by the overlapping of the first and second ends of the wall body”, correcting a previously overly narrow interpretation. It clarified that this technical feature is not limited solely to a slot formed by the overlapping of the ends of a plate, but also encompasses a flow-guiding opening structure formed by the overlapping of the boundaries of the wall body. Based on this interpretation, the court held that although the accused infringing product utilised multiple sets of flow-out openings, its structural configuration and fluid-adhering flow-guiding effect closely corresponded to the technical features of the flow-out channel defined in the patent claims, and that the accused infringing product therefore fell within the scope of protection of the patent in question.
On the issue of jurisdiction, the court, relying on the Restatement of the Brussels Regulation and the UPC Agreement framework, clarified that the UPC, as a common court of the member states, possesses international jurisdiction over the defendant companies established in Sweden, the Netherlands and Germany, and may adjudicate on their conduct within UPC member states and Spain. At the same time, the court rejected the approach of using the Dutch company as an ‘anchor defendant’ to extend jurisdiction to the UK market, noting that its status as an EU authorised representative was insufficient to establish joint infringement or intermediary liability in the UK; consequently, the claims against the UK defendant were dismissed.
Regarding the issue of whether to grant an injunction, the court held that the validity of the patent in question was currently established and that the grounds for invalidity raised by the defendant were unfounded. Furthermore, as the parties were in direct competition, the continued sale of the accused products would cause actual and irreparable harm to Dyson’s market interests. Taking into account the difficulties of enforcing damages across borders, the court deemed it necessary to adopt urgent relief measures to prevent the relevant infringing acts.
Ultimately, the court issued a provisional injunction against the relevant parties within the UPC member states and Spain, prohibiting them from manufacturing, selling, importing and stocking the products in question, with a maximum fine of €250,000 for any breach of the injunction.
Case Background
On 2 May 2025, Dyson filed an application for interim measures with the Hamburg Regional Division of the UPC, alleging that Dreame’s older and newer models of hair styling products infringed its patents, and requesting the court to prohibit the sale of the relevant products within the UPC’s jurisdiction and in Spain (Case No.: ACT_20368/2025);
On 14 August 2025, the Hamburg Regional Division of the UPC found that the “Dreame Airstyle” and “Dreame Pocket” models sold by Dreame in Europe infringed Dyson’s European patent EP 3 119 235, but held that the open-hole fluid outlet of the newer models did not constitute the “overlapping structure” defined in the patent, and therefore did not grant an injunction against the newer models; The scope of the injunction covers all defendants within the UPC’s jurisdiction, with the Spanish jurisdiction limited to Dreame International and Eurep, whilst imposing a maximum penalty of €250,000 for each instance of infringement (Case No. UPC_CFI_387/2025);
In September 2025, both Dyson and ZuiMi appealed against the judgment, with case numbers APL_35434/2025 and APL_35749/2025 respectively, concerning patent EP3119235;
On 15 September 2025, Dyson formally brought patent infringement proceedings against Dreame before the Hamburg Regional Division of the Unified Patent Court (UPC) (Case No. ACT_36443/2025);
On 6 March 2026, the Appeal Chamber of the Unified Patent Court (UPC) dismissed ZuiMi’s appeal, upheld Dyson’s application for interim measures, and extended the scope of the injunction against infringement of European Patent No. EP 3 119 235.
Attached: Judgment
