Dyson v. Dreame Patent Infringement

On March 6, 2026, the Court of Appeal of the Unified Patent Court (UPC) issued two crucial rulings in the patent infringement dispute between Dyson and Dreame, marking significant progress in this closely-watched patent battle.

The dispute concerns Dyson's European Patent No. EP3119235, which protects a curling attachment for hand-held hair styling devices, particularly a technical structure for automatic hair curling based on the "Coanda Effect." Dyson applies this technology in its Airwrap styler products.

The accused infringing products are Dreame's AirStyle and Pocket series stylers, which are alleged to fall within the scope of protection of the said patent.

On May 2 last year, Dyson filed an application for preliminary measures with the UPC Local Division Hamburg. On August 14, the Local Division Hamburg issued a ruling, finding that Dreame's old models infringed the patent and imposing an injunction against them, but held that the new models (Pro series) did not constitute infringement and denied the injunction against the new models. In September, both Dyson and Dreame appealed.

In March this year, the Court of Appeal made two key rulings:

Expansion of the Injunction Scope: The preliminary injunction was extended to cover Dreame's relevant new models, including the "Dreame Airstyle Pro," "Dreame Pocket Neo," and the latest models "Dreame Airstyle Shine Multi Hairstyler" and "Dreame Pocket Pro."

In this ruling, the Court of Appeal clarified the interpretation standard for the core feature of the patent, "the slot is formed by the overlapping of the first end and the second end of the wall." It stated that when interpreting claims, not only the function of the relevant structure should be considered, but also the physical structure and spatial configuration disclosed in the patent specification and drawings must be taken into account. Therefore, the determination of "overlapping" should be conducted from a perspective "substantially perpendicular to the outer surface of the first end of the wall," rather than from the "radial perspective" advocated by Dreame.

The Court of Appeal held that although the new models (Airstyle Pro and Pocket Neo) adopt a fluid outlet structure with openings on the wall, the ends of the wall at the boundaries of the openings still form the overlapping structure defined in the claims, thus also satisfying the technical features of the patent. The technical features of the latest models (Airstyle Shine Multi Hair styler and Pocket Pro) are substantially the same as those of the aforementioned new models, and there is also a high likelihood of infringement.

The Court pointed out that Article 62(1) of the Agreement on a Unified Patent Court does not require the injunction to be limited strictly to the specific acts of infringement already committed by the infringer. As long as the fact of patent infringement exists, a risk of continuing or repeating the infringing acts can be reasonably presumed. Accordingly, the injunction was extended to cover Dreame's relevant new models.

Referral to the CJEU: The Court stayed the proceedings concerning the Spanish territory and the proceedings against the EU representative, Eurep GmbH. It referred four questions on the interpretation of EU law to the Court of Justice of the European Union (CJEU) for a preliminary ruling.

Currently, the preliminary injunction has taken effect within the UPC member states. The part concerning Spain and Eurep GmbH will await the preliminary ruling from the CJEU. China Intellectual Property Lawyer Network will continue to follow the subsequent developments.