Koninklijke Philips v Belkin International (CFI, 11 February 2026)

Dhenne Avocats · 10 October 2026

Our analysis

Summary

The Munich Local Division upholds the infringement action brought by Koninklijke Philips N.V. against Belkin International, Inc., Belkin B.V. and Belkin Limited on EP 2 867 997 (wireless inductive power transfer), concerning Qi2 chargers implementing the Magnetic Power Profile (MPP). The decision, given orally on 11 February 2026 with written reasons dated 23 April 2026, rejects a res judicata objection based on earlier proceedings concerning Qi devices, finds direct and indirect infringement, holds liable the group companies that issued the EU declarations of conformity or acted as authorised representative, and dismisses the FRAND defence. For practitioners, it shows that notice given through a patent pool may suffice and that a defendant who provides neither security nor sales information cannot rely on the FRAND defence.

Facts and procedure

The patent had already been asserted before the same division (UPC_CFI_390/2023) against devices complying with earlier versions of the Qi standard, a case decided on appeal by the Court of Appeal (UPC_CoA_534/2024). The present action targets Qi2 power transmitters with MPP. The defendants denied infringement, invoked a licence covering compatible products and raised a FRAND defence. They also asked for a court-appointed expert and for the admission of a brief filed on 6 February 2026.

The applicable law

The division applies Articles 25, 26 and 63 UPCA, Rule 362 RoP on res judicata and Rule 118.8 RoP on corrective measures. On FRAND, it reasons from the CJEU judgment in Huawei v ZTE (C-170/13). It considers itself bound by the construction of claim 20 adopted by the Court of Appeal in UPC_CoA_534/2024.

Question

Do Qi2 chargers implementing MPP infringe the patent, are the group companies involved in placing them on the market liable, and may the defendant raise a FRAND defence where notice was given through a pool and no security was provided?

Decision

The action is not barred, since its subject-matter differs from the earlier action (section I). Claim 20 is construed in line with the Court of Appeal: features 20.6 and 20.6.1 do not require the transmitter to be able to reject entry into negotiation (sections II and III). Setting the MPP Full Mode bit is a request to enter the negotiation phase and the MPP acknowledgement pattern signals acceptance, so claim 20 is directly infringed and claims 1, 17 and 19 indirectly (section IV). Belkin Limited is the principal infringer. Belkin International and Belkin B.V. are liable at least as accessories, since without them the products could not have been marketed in the Contracting Member States. The division distinguishes the approach of the Hamburg Local Division and the Court of Appeal on authorised representatives, relying on the group’s knowledge of the dispute (section V). The licence argument, raised shortly before the hearing, is not taken into account (section VI). On FRAND, the division assumes dominance without deciding it, the defendants having failed to define the market consistently, finds notice sufficient through the negotiations with a pool covering Qi2, and notes the lack of security and sales information. It does not examine whether the offer was FRAND (section VII). The operative part orders an injunction for Germany, Belgium, France, Finland, Italy, the Netherlands, Austria and Sweden, recall and destruction, information within 60 days, provisional damages of EUR 127,000, assessed by reference to the court fees (EUR 15,000) and representation costs (EUR 112,000) asserted (section IX), publication at the claimant’s expense, penalty payments and costs.

Key points for practice

• A fresh action on the same patent against a later version of the standard is not barred by res judicata where the embodiments differ (section I).
• Issuing the EU declaration of conformity or acting as authorised representative may make a group company liable where the group was aware of the dispute (section V).
• Negotiations with a pool covering the standard may amount to notice, further notices for each version of the standard being a mere formality (section VII).
• Practical point: a defendant intending to rely on a licence or on FRAND must do so early and provide security together with sales information (sections VI and VII).

Provisions applied

Agreement on a Unified Patent Court

Arts 25, 26, 62, 63, 73(1) and 82

Rules of Procedure

Rules 9.1, 36, 118.7, 118.8, 185, 190, 191 and 362

Case law cited

Belkin v Koninklijke Philips, Court of Appeal, 3 October 2025 (UPC_CoA_534/2024), Court of Appeal, 13 May 2024, UPC_CoA_1/2024, Alexion v Amgen, Court of Appeal, 20 December 2024, UPC_CoA_405/2024, UPC_CFI_9/2023, Hamburg Local Division, UPC_CFI_387/2025, Court of Appeal, 6 March 2026 (UPC_CoA_789/2025).

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.