Multi-jurisdictional patent litigation

Multi-jurisdictional (patent) litigation refers to all disputes relating to the same patent (or a group of related patents) that extend across several territories or countries. It is characterized by parallel or successive proceedings before different national or regional jurisdictions, where the rules of procedure and procedure can vary significantly (deadlines, evidence, sanctions, etc.). This situation frequently arises when a patent holder claims to assert their rights in several markets, or when an alleged infringer carries out an activity covering several countries.

The complexity of this litigation is due in particular to differences between national laws (methods of proof, investigative measures, calculation of damages) and to overlapping jurisdictions (for example, national courts, the European Patent Office, potentially the Unified Patent Court (UPC) in some EU Member States). The litigant must then navigate between several procedural systems, which can multiply costs and increase legal uncertainty.

The challenge remains to coordinate these actions in such a way as to effectively protect the patent in each territory concerned, while reducing the risk of contradictory decisions.