On August 10, 2026, the Hague Regional Division of the Unified Patent Court (UPC) issued a judgment in the patent infringement and counterclaim for invalidity case brought by Maxell Ltd. against Samsung Electronics Co., Ltd. and others. The court ruled that European Patent EP 2 061 230 (EP230), held by Maxell, was invalid and dismissed Maxell’s infringement claims against Samsung’s Galaxy series of smartphones and tablets.
Case Background
Maxell is a Japanese consumer electronics company that holds European Patent EP 2 061 230. The patent, titled “Portable terminal, information processing apparatus, and content display system,” relates to technology for content transmission and display switching between mobile terminals and external devices.
The patented solution is primarily used to enable seamless content playback across different devices. For example, a user can watch a video or browse content on a smartphone and then switch the content to an external device, such as a television, to continue playback. During the switching process, the mobile terminal sends information to the external device to identify the content; the external device then retrieves and displays the corresponding content, while the mobile terminal can continue to control playback on the external device.
Maxell contends that the relevant features in Samsung’s Galaxy series of smartphones and tablets infringe claims 1, 2, 5, and 6 of EP230. Consequently, Maxell filed a lawsuit with the UPC, requesting the court to prohibit Samsung from continuing such acts and to order measures such as product removal from the market, destruction, recall, and disclosure of information. Samsung denies the allegations of infringement and filed a counterclaim arguing that the patent lacks novelty and inventive step, requesting the court to revoke the patent.
The Court’s Ruling
In its examination of the validity of EP230, the UPC focused on analyzing whether the prior art document D3 (US 2006/0263048 A1) submitted by Samsung had already disclosed the core technical solution of the patent in question.
The prior art document D3 submitted by Samsung also relates to a content display system in which a user can control another playback device via a mobile terminal and transfer the content currently being played to that device. In this technical solution, the controlling device sends information identifying the content and the playback position to the playback device to enable content switching.
Samsung argued that D3 had disclosed the cross-device content switching scheme claimed by EP230. In response, Maxell contended that differences still existed between EP230 and D3: specifically, EP230 required that the data transmitted between devices include not only content identification information but also “history information” reflecting the user’s previous operational status, whereas the playback position data in D3 did not meet this requirement.
In response, the court held that the “history information” in the patent-in-suit does not require the recording of a complete log of multiple operations; as long as the relevant information reflects the user’s prior operations and affects the content display status, it satisfies the relevant technical features. Therefore, the playback position data generated when the user pauses playback also constitutes information reflecting the user’s operation history. Based on the above determination, the UPC ruled that D3 had disclosed all the technical features of Claim 1 of EP230, and that the patent-in-suit lacked novelty.
To preserve the validity of the patent in question, Maxell filed several auxiliary requests, seeking to distinguish the patented solution from the prior art by narrowing the scope of protection of the claims, with the aim of retaining patent protection for certain technical solutions. Among these, AR7a and AR8a further added content feedback, authentication information, remote control, and restrictions on Internet URL content.
However, the UPC held that there was no functional interaction among these added technical features, and they did not produce a synergistic technical effect beyond the simple aggregation of their individual technical contributions. The court noted that, in assessing inventive step, a claim cannot be deemed inventive merely because it includes multiple technical features. If different technical features each perform independent functions and a person skilled in the art can combine them based on the prior art or conventional technical means, then the solution may still be considered obvious.
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