Maxell’s Screen-Casting Patent Invalidated in Its Entirety by Samsung at the UPC

The Hague Local Division of the Unified Patent Court (UPC) rendered a first-instance judgment on 10 August 2026 in the patent infringement dispute brought by Japanese company Maxell, Ltd. against Samsung Electronics Co., Ltd. and its European affiliates. The court dismissed all of Maxell’s infringement claims and, concurrently, declared European Patent No. EP 2 061 230 invalid in its entirety across all designated contracting member states.

According to the operative part of the judgment, Maxell is ordered to pay Samsung litigation costs in the amount of EUR 400,000, as previously agreed between the parties through mutual consultation—EUR 200,000 attributable to the infringement proceedings and EUR 200,000 to the invalidity counterclaim. The cost order takes effect immediately. Maxell, Ltd., headquartered in Tokyo, is a multinational technology enterprise that started as a battery manufacturer and later expanded into a diversified electronics company. The case has drawn significant industry attention as it involves content projection and seamless switching technologies among smart devices.

The patent-in-suit, EP 2 061 230, entitled “Portable Terminal, Information Processing Apparatus, and Content Display System,” is directed to a core technical solution for, when a user transfers Internet content being played or displayed on a portable terminal (e.g., a mobile phone) to an external information device (e.g., a television) through a “flick operation,” synchronously transmitting data reflecting the user’s historical operation state—including scroll position, playback progress, and authentication information—so that the external device can seamlessly resume display from the same state.

In addition, the patent also covers an arrangement for “returning” display content from the external device back to the portable terminal. Maxell alleged that Samsung’s Galaxy-series smartphones and tablet computers fell within the scope of claims 1, 2, 5, and 6 of the patent, thus constituting direct infringement. Samsung, in its defence, simultaneously filed a counterclaim for invalidity, arguing that the patent lacked novelty and inventive step, and also contained added subject matter extending beyond the content of the application as originally filed, and thus should be revoked in its entirety.

In the invalidity examination of the present case, the court focused on claim 1 of the granted version as asserted by Maxell. The central point of dispute between the parties was whether the “playback stop position” recited in document D3 constituted “history information” within the meaning of the patent.

Maxell contended that this was merely progress data automatically recorded by the system, but the court did not accept that argument. The court explicitly held that the term does not require the recording of multiple operations, nor does it necessarily require a complete operation log; a display state outcome resulting from a single operation (such as a playback stop position) may equally qualify as history information. Since D3, in describing the “flick operation,” expressly discloses transmitting that position information together with content identification information to the external device, the court found that claim 1 lacked novelty. Independent claims 11 and 17 were consequently also invalidated on the same ground.

After the granted version was declared invalid, Maxell filed ten auxiliary requests, progressively limiting the claims by introducing additional features such as “return function,” “authentication information,” “remote control function,” and “Internet or URL limitation.” However, the court ultimately found that all these auxiliary requests failed for lack of inventive step.

The judgment was rendered and pronounced orally in English on 10 August 2026. Under the Rules of Procedure of the Unified Patent Court, either party may appeal this decision to the UPC Court of Appeal within two months from the date of notification of the judgment. This ruling once again confirms the UPC’s consistent position that claim construction should not be unduly narrowed. China Intellectual Property Lawyer Network will continue to follow subsequent developments.