Centripetal v Palo Alto Networks (CFI, 19 December 2025)

Dhenne Avocats · 10 October 2026

Our analysis

Summary

In a decision of 19 December 2025, given in infringement action UPC_CFI_660/2024 and counterclaim for revocation UPC_CFI_134/2025, the Mannheim Local Division revoked in full, for France and Germany, Centripetal’s patent EP 3 652 914 on accelerating cyberanalysis workflows, dismissed the application to amend and its many auxiliary requests, and dismissed Centripetal’s action against Palo Alto Networks. The main request lacked novelty over US’358 (HAWK), and the proposed amendments lacked novelty or inventive step. The decision illustrates a request-by-request review of a machine learning based cybersecurity patent.

Facts and procedure

The patent, filed on 10 July 2018 with a US priority of 10 July 2017, is in force in France and Germany. Its opt-out was withdrawn on 5 November 2024. Centripetal targeted Cortex XSIAM, Cortex XDR (SmartScore function) and the next generation firewalls running PAN-OS, seeking among other things an injunction, an interim award of EUR 100,000 and publication of the decision. Palo Alto Networks counterclaimed for revocation. Centripetal defended a combination of claims 1, 2, 10 and 14 as its main request and twelve groups of amendments as auxiliary requests. The hearing took place on 17 November 2025.

The applicable law

The counterclaim falls under Article 65(2) UPCA and Article 138(1)(a) and (b) EPC, with novelty and inventive step assessed under Articles 54 and 56 EPC. The admissibility of late submissions was considered under Rule 263 in relation to the amendment of the patent (paragraphs 30 and 31).

Question

Is the claimed combination of event logs, a static algorithm and a machine-learned algorithm to estimate the likelihood that a threat event should be reported new and inventive over HAWK, and can any of the proposed amendments save the patent?

Decision

The division construed the claims broadly: event logs need not be firewall output (paragraphs 49 to 59), the static algorithm is one that is not self-learning (paragraphs 65 to 69), the machine-learned algorithm is not limited to any type (paragraphs 70 to 77) and the likelihoods may be combined in any way (paragraphs 78 to 80). On that basis, HAWK discloses every feature of the main request, its naive Bayes classifier being a machine-learned algorithm (paragraphs 109 to 134). Amendments 1 to 3 lacked novelty (paragraphs 136 to 144). The others lacked inventive step: HAWK is a realistic starting point, artificial neural networks belong to common general knowledge and the HLCC17 document teaches their use for threat scoring (paragraphs 155 to 172 and 185 to 222). As the patent was revoked, the infringement action was dismissed without a separate infringement analysis (paragraphs 223 and 224). Centripetal bears the costs, the value in dispute being set at EUR 1,000,000 for each claim (paragraphs 225 and 226).

Key points for practice

• A broad claim construction widens the relevant prior art accordingly, as HAWK shows.
• For machine learning inventions, a generic term such as « machine-learned algorithm » covers a known naive Bayes classifier (paragraphs 70 to 77 and 109 to 134).
• Multiplying auxiliary requests offers no protection where each adds features belonging to common general knowledge.
• Practical point: before suing on a software patent, the proprietor should test each fallback position against academic prior art, which the defendant may file with its counterclaim.

Provisions applied

Agreement on a Unified Patent Court

Art. 65(2) and Art. 69(1)

Rules of Procedure

Rules 30.1, 118.5 and 263

European Patent Convention

Art. 54, Art. 56, Art. 83 and Art. 138(1)(a) and (b)

Case law cited

CeraCon v Sunstar Engineering, Court of Appeal, 2 September 2025, Amgen v Sanofi-Aventis Deutschland, Court of Appeal, 25 November 2025, Meril v Edwards Lifesciences, Court of Appeal, 25 November 2025, Abbott Diabetes Care v Sibio, Court of Appeal, 14 February 2025, Sanofi-Aventis Deutschland v Amgen, 16 July 2024, Grundfos v Hefei Xinhu Canned Motor Pump, 8 May 2025, Paris Central Division, 21 January 2025 (UPC_CFI_311/2023), Mannheim Local Division, 2 April 2025 (UPC_CFI_359/2023) and 6 June 2025 (UPC_CFI_471/2023)

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.