Centripetal v Palo Alto Networks (CoA, 4 February 2026)

Dhenne Avocats · 10 October 2026

Our analysis

Summary

In an order of 4 February 2026 (UPC_CoA_891/2025), the Court of Appeal dismissed Centripetal Limited’s appeal against the Mannheim Local Division’s order of 2 October 2025 which, on Palo Alto Networks, Inc.’s request for review, had revoked the saisie order based on EP 3 821 580 and dismissed the application for preserving evidence and inspection. Centripetal no longer defended the order as issued and instead sought to have it maintained in an amended form put forward for the first time on appeal: the Court held that request inadmissible.

Question

Is a request to maintain a saisie order in an amended form, made for the first time on appeal, admissible under Rule 222.2?

Decision

The Court may disregard requests not made at first instance, having regard to whether they could reasonably have been made earlier, their relevance and the other party’s position (paragraph 15). Although some requests had been withdrawn, the amended version broadened the order: it covered documents not located at the Munich office and a broader or less defined category of « detailed descriptions » (paragraph 16). Centripetal gave no reason for not filing it earlier, the amendment raised new questions on the place of execution and the definition of the evidence, and its late filing seriously prejudiced Palo Alto’s defence (paragraph 17). The conditional request to join Palo Alto Networks (Germany) GmbH therefore fell away (paragraph 18). As the original order was not defended, its revocation stood (paragraph 19) and Centripetal bears the costs of the appeal (paragraph 20).

Key points for practice

• Practical point: an applicant wishing to reframe a saisie after its revocation must do so during the review proceedings at first instance, a broader version first put forward on appeal will be disregarded.

Provisions applied

Rules of Procedure

Rules 197.3 and 222.2

Related decisions

• Centripetal v Palo Alto Networks, 2 October 2025, review order revoking the saisie, upheld.
• Centripetal v Palo Alto Networks, 28 May 2025, Court of Appeal order remitting the application to Mannheim.

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.