Hewlett-Packard Development v Andreas Rentmeister (CFI, 11 November 2025)

Dhenne Avocats · 10 October 2026

Our analysis

Summary

By an order of 11 November 2025 (UPC_CFI_515/2025, EP 3 835 965), the Düsseldorf Local Division held, on a reasoned request by Hewlett-Packard Development, that the steps already taken to bring its application for provisional measures to the attention of Shenzhen Moan Technology constituted good service (Rule 275.2). Service through the Hague Convention channel had stalled in China since June 2025. The order confirms a useful practice for urgent cases against defendants based in China.

Question

In provisional measures proceedings, may the division treat service on a Chinese defendant as good where transmission through the Central Authority has not been completed and the six-month period under the Hague Convention has not expired?

Decision

Rule 275.2, which refers to the statement of claim, applies a fortiori to an application for provisional measures, given the urgency (paragraphs 9 and 10). The formal routes under Rules 270 to 274 were exhausted: the request reached the Supreme People’s Court on 19 June 2025 with no further progress, the division’s enquiries and the email sent to the defendant went unanswered (paragraphs 11, 14 and 15). Article 15(2) of the Hague Convention does not stand in the way in summary proceedings, since Article 15(3) preserves provisional measures in urgent cases (paragraph 13). Service takes effect on the date of the order, which is published on the UPC website so that the defendant can learn of it (paragraphs 17 and 18 and order).

Key points for practice

• In urgent cases, an applicant for provisional measures can obtain deemed good service without waiting six months, provided it documents the failure of the Hague route and its attempts at direct contact.

Provisions applied

Rules of Procedure

Rules 209.1, 270 to 274 and 275

Hague Convention of 15 November 1965 on the Service Abroad

Art. 15(2) and (3)

Case law cited

Hewlett-Packard Development v Zhuhai Ouguan Electronic, Düsseldorf Local Division, 16 October 2025, Panasonic v Xiaomi, Mannheim Local Division, 31 July 2024 (UPC_CFI_330/2024)

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.