Centripetal v Palo Alto Networks (CFI, UPC_CFI_636/2025, 2 October 2025)

Dhenne Avocats · 10 October 2026

Our analysis

Summary

In an order of 2 October 2025 (UPC_CFI_636/2025), the Mannheim Local Division, on a request for panel review under Rule 333, confirmed the judge-rapporteur’s order of 25 July 2025 refusing to impose penalties on Palo Alto Networks for non-compliance with a saisie order. The order clarifies the scope of the defendant’s duty: it must tolerate inspection of the premises and items described, but need not create access rights or set up a system that is not present on site.

Question

Does a defendant breach an order for seizure and monitoring of its system when, at the designated premises, it declines to extend an employee’s access rights or to have the system set up from its US headquarters?

Decision

The request for panel review was rejected. Inspection is confined to the premises and items described in the order, and the defendant only has to tolerate it: it need not raise a sales employee’s access rights beyond what ordinary business requires, all the more so since the premises visited belonged to a separate affiliate. The Court of Appeal’s order did not require the defendant to set up a system that was not physically there (paragraph 6). The panel exercised its discretion in the same way as the judge-rapporteur (paragraph 7) and noted that the saisie order, having been reviewed and revoked save for its confidentiality part, could no longer serve as a basis for enforcement (paragraph 8). Leave to appeal was refused.

Key points for practice

• Enforcing a saisie requires targeting the right premises and the right entity: the defendant’s duty remains passive.
• An applicant seeking access to a digital system must provide for it precisely in its application, since the order cannot be widened at the enforcement stage.

Provisions applied

Agreement on a Unified Patent Court

Art. 60(3)

Rules of Procedure

Rules 192.2(b), 199 and 333

Directive 2004/48/EC

Art. 7

Other provisions

European Convention on Human Rights, Art. 8, Charter of Fundamental Rights of the European Union, Art. 7, Regulation (EU) 2020/1783

Case law cited

Centripetal v Palo Alto Networks, Court of Appeal, 28 May 2025, C-Kore Systems v Novawell, Paris Local Division, 1 March 2024

Related decisions

• Centripetal v Palo Alto Networks, 25 July 2025, judge-rapporteur’s order confirmed.
• Centripetal v Palo Alto Networks, 2 October 2025, order of the same day on review of the saisie order.

Prepared by Dhenne Avocats from the official decision, consulted on 10 October 2026. The database is updated every week, on Friday. Only the official text is authoritative.