Recently, the global dispute over standard essential patent (SEP) licensing has escalated once again. The Local Division Mannheim of the UPC and a German court have issued an injunction to prohibit Geely from filing global interim license applications with Hangzhou Intermediate People’s Court, the application claims that two parties  first sign a global provisional patent license agreement before the Chinese court makes a final ruling on the global FRAND rate.                                                                                                                                                                                                                                         

The issuance of the injunction mentioned above further highlights the intensifying jurisdictional conflicts among nations in cross-border SEP disputes.

The case originates from a licensing dispute between Nokia and Geely concerning cellular communications SEPs. Although Geely's subsidiaries Volvo and Polestar have already obtained licenses under the Avanci 5G vehicle licensing program (in which Nokia is one of the licensors), Geely's parent company itself has not yet entered into a bilateral license or patent pool license with Nokia.

In July 2025, Nokia filed patent infringement lawsuits against Geely in multiple jurisdictions, including the Mannheim and Munich Local Divisions of the UPC and the Munich Regional Court in Germany.

Just days after Nokia’s filing its lawsuits, Geely filed an action in July 2025 with the Hangzhou Intermediate People's Court, requesting that the Chinese court determine a global FRAND license fee rate covering SEPs for 2G through 5G and WLAN.

Based on that, on April 8, 2026, Geely further filed an application for an interim license with the Hangzhou court, requesting the court to compel the parties to enter into a global interim license agreement before a final rate ruling is made.

Geely has stated that Nokia failed to fulfill its FRAND obligations in licensing negotiations and that Nokia is coercing Geely to accept excessively high rates "beyond FRAND" with the threat of injunctions from the UPC and German courts. Geely also noted that similar strategies have been used against Daimler, OPPO, Lenovo, and Sunmi.

In face of Geely's pursuit of an interim license in China, Nokia filed an emergency application with the Mannheim Local Divisions of the UPC to seek interim measures. Nokia believed that Geely's interim license application aimed at interfering with Nokia's ability to lawfully enforce its patent rights in European courts, and that any ruling by the Chinese court on the matter would infringe upon Nokia's European patent rights and violate the principle of international comity.

On April 20, 2026, in favor of Nokia, the UPC Mannheim Local Division issued an Anti-Anti-Suit Injunction (AASI) against Geely to prohibit Geely from filing global interim license applications with Hangzhou Intermediate People’s Court, holding that a mandatory interim license imposed by a Chinese court would substantially interfere with Nokia's European patent rights and violate the principle of international comity. The court also clarified that the scope of this injunction covers Geely's entire action related to a global FRAND rate determination. At the same time, the Munich Regional Court in Germany issued a similar AASI against Geely.

Nokia issued an announcement saying that these measures "are defensive in nature and aim to safeguard its right to enforce patent rights in Europe in accordance with the law," and emphasized that the applications "do not interfere with the rate-setting proceedings in China."

It is worth noting that this case is not an isolated incident. Previously, the UPC and German courts have issued similar measures in related cases to protect their own jurisdiction. In the case InterDigital suing Amazon, the UPC Mannheim Local Division and the Munich Regional Court issued an AASI against Amazon in the fall of 2025, prohibiting Amazon from seeking interim SEP license relief in UK courts, on the same grounds that such interim relief would improperly interfere with litigation in Europe. Those injunctions subsequently triggered countermeasures from UK courts, resulting in a chain of competing anti-suit and anti-anti-suit injunctions, a jurisdictional conflict continues till now.

This case is also based on the backdrop of long-standing institutional disputes between China and Europe over SEPs. Previously, the European Union initiated a dispute settlement proceeding (DS611) at the WTO regarding Chinese courts' use of anti-suit injunctions in SEP cases, and obtained arbitration support in July 2025, with China committing to adjust its rules on anti-suit injunctions. Additionally, new progress has been made on another WTO complaint (DS632) filed by the EU concerning Chinese courts' determination of global FRAND rates without the consent of both parties saw in February 2026, with the EU requesting the establishment of a dispute settlement panel.

Meantime, China's State Council recently issued and put into effect the *Regulations of the People's Republic of China on Countering Foreign Unjustified Extraterritorial Jurisdiction, explicitly prohibiting any organization or individual from implementing or assisting in the implementation of unjustified extraterritorial foreign measures, and establishes supporting systems such as identification and blocking mechanisms, a list of malicious entities, and enforcement injunctions. Whether the AASI issued by the UPC and German courts against Geely's China litigation will trigger blocking or countermeasures under these Regulations worth continuous attention.

From IP Forefront

April 23th, 2026