UPC Mannheim Rules in InterDigital v. Disney: Finds Disney+ Encoding Technology Infringing

On June 16, 2026, the Mannheim Local Division of the Unified Patent Court (UPC) issued a final judgment in the patent infringement case brought by InterDigital against The Walt Disney Company. The decision is groundbreaking on multiple legal issues, notably clarifying that intangible video signals transmitted over a network can be protected as "products" under patent law, thereby establishing an important precedent for patent enforcement in the digital streaming era.

The claimant, InterDigital VC Holdings, Inc., is a Delaware-based research and development company holding European Patent EP 2 465 265, which relates to intra-frame chrominance coding technology in video encoding, particularly concerning methods for the independent or responsive determination of luminance and chrominance partition types, and the encoded signals generated thereby.

The defendants are The Walt Disney Company and its 11 affiliated entities, including subsidiaries responsible for operating its streaming service "Disney+." Disney provides a vast array of audiovisual content globally through Disney+, employing the HEVC (H.265) standard for video encoding.

InterDigital alleged that the encoded video data streams provided by Disney infringed claim 1 and claim 15 of the asserted patent.

Disney contended, inter alia, that claim 15 of the patent-in-suit protects a "signal," and that a signal, being an intangible data stream, does not qualify as a "product" in the traditional sense of patent law and therefore should not be subject to patent infringement regulation.

The UPC Mannheim Local Division, after hearing, held that "a non-physical signal sequence, such as an encoded video data stream transmitted over a data network, even if not fixed on a permanent physical medium, falls within the meaning of 'product' under Article 25(a) of the Agreement on a Unified Patent Court and is entitled to product protection." The court explained that, in the field of data processing, there is no relevant technical difference between a sequence stored on a data carrier and one transmitted solely over a network; the data carrier is merely a storage medium, and its intended use for the data is immaterial. This interpretation removes the object-matter barrier for patent infringement litigation in the fields of streaming, cloud services, and digital content distribution.

After construing the claims, the court found that the encoded video data provided by Disney through the Disney+ service fully embodied all the technical features of independent claims 1 and 15.

In particular, under the 4:2:0 sampling mode of the HEVC standard, the encoder supports multiple chrominance partition types (16×16, 8×8, 4×4), and the determination of the chrominance partition type depends on the selected luminance partition type, which falls within the scope of "responsive to." At the same time, the set of chrominance partition types differs from the set of luminance partition types in at least one dimension, satisfying the "different sets" requirement and not falling into the "always identical" prior art pattern.

Because Disney, in the operation of the service, provides and places on the market the encoded signals, it directly infringed product claim 15 and also constituted use of method claim 1. Consequently, the court enjoined Disney from offering or placing on the market the infringing encoded video data and signals in the 11 UPC member states.