The UPC is up and running, and considering its first FRAND cases. English and German courts have approached the question of injunctions in cases in different ways: the English court focusing on determining a FRAND rate which the infringer may agree to avoid injunction, whilst the German Court decides whether to grant an injunction under the fault-based approach in Huawei v. ZTE. This article considers which practices of the English and German Courts the UPC might adopt in FRAND cases, and what i
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