Dyson and DLA land PI over Dreame hair stylers in UPC territory and Spain

Since the Düsseldorf local division’s judgment in FujiFilm vs Kodak, the UPC’s so-called long-arm jurisdiction has become one of the most discussed topics among patent experts. Initially, at the beginning of 2025, the Düsseldorf local division only indicated jurisdiction for one country outside the UPC territory, namely the UK. Then, in July, the Mannheim local division issued an injunction against Kodak for the UK.

Now the court has once again extended its reach beyond its 18 member states. The local division Hamburg under presiding judge Sabine Klepsch has prohibited the Chinese manufacturer Dreame from distributing certain hair styling devices in the UPC territory and Spain by preliminary injunction (case ID: UPC_CFI_387/2025). Stefan Schilling is the judge-rapporteur in the case. Stefan Johansson, from the Nordic-Baltic regional division was the third judge.

Dyson sees its EP 3 119 235 infringed. The patent relates to an attachment for a handheld device, particularly a hair care appliance such as a hot styling brush. Dyson itself sells the Dyson Airwrap, which can be used to curl hair. Dreame sells a competing product under the brands Dreame AirStyle and Dreame Pocket. According to Dyson, these infringe EP 235.

The local division Hamburg has now prohibited the sale of the older versions. The judgment has already taken effect and is immediately enforceable. JUVE Patent does not know whether Dyson has enforced it yet.

In a statement to JUVE Patent, Dreame pointed out that it is reviewing the option to appeal. Dreame also stated that it is “delighted that the court acknowledged that its main products Dreame Airstyle Pro and Dreame Pocket Neo are not infringing Dyson’s patent neither in the UPC territory nor in Spain”.

These products are still available, for example via Dreame’s German online Store, while the older versions are no longer sold here.

Jurisdiction for Spain

In the dispute between Fujifilm and Kodak, the local division Düsseldorf stated that if the defendant is based in a UPC member state, the court has jurisdiction to hear the case regarding the UK part of the European patent-in-suit. The local division Mannheim later followed suit and issued the injunction for the UK.

However, the Hamburg local division has now gone one step further in its judgment. Dyson had sued the Chinese parent company Dreame International as well as a Swedish subsidiary, a German sales partner and Eurep GmbH in Ingolstadt. The latter company acts as an authorised representative for manufacturers based in a non-EU member state and as EU representative of Dreame.

Eurep is therefore an anchor defendant and the local division Hamburg has now also prohibited Dreame International and Eurep from selling hair stylers in Spain.

Unlike the UK, Spain decided against participating in the UPC from the outset and did not sign the UPC Agreement. The UK only subsequently withdrew from the UPC project following Brexit.

Detailed justification

The judges provide detailed justification for the PI regarding Spain in their ruling. The headnotes state: “In order to establish international jurisdiction for the alleged infringement of the national part of a European patent outside of the UPCA-countries requires at least the plausible allegation of infringing acts by that party in the country in question (here Spain).”

Additionally, the judges write that “as it is not possible for non-EU based manufacturers to sell electronics in the EU without an Authorized Representative in the Union (regulations 2023/988/EU on general product safety and 2019/1020/EU on market surveillance and compliance of products), the legal framework puts the Authorized Representative in the role of being an indispensable party in the distribution of electronic products. Thus, an Authorized Representative can serve as an anchor defendant with respect to Art. 8 (1) Brussels I recast regulation (1215/2012/EU)”.

The ruling concludes: “An Authorised Representative in the Union (regulations 2023/988/EU on general product safety and 2019/1020/EU on market surveillance and compliance of products) is an intermediary and can as such be subject to an injunction, Art. 63 (1) 2nd sentence UPCA.”

Shortly after the PI from Hamburg, the local division The Hague also affirmed the jurisdiction of the UPC for Spain in the suit filed by Genevant Sciences and Arbutus Biopharma against 15 Moderna subsidiaries, including the Spanish subsidiary (case ID: 191/2025 and 192/2025).

DLA again for Dyson

Dyson is one of the companies that used the UPC very early on. The company initially sued SharkNinja for handheld vacuum cleaners in 2023. Both companies ended the dispute at the turn of 2024/25.

DLA Piper partner Constanze Krenz already had the lead for Dyson at that time and is also representing the company in the PI case against Dreame. Other team members are senior associate David Kleß and associates Julia Pehe and Joschua Fiedler, all from DLA’s Munich office.

Dreame is represented in the dispute by Hogan Lovells. Anna-Katharina Friese-Okoro and Christian Stoll from the Hamburg office have the lead.

This article was updated on 22.8.25 to include additional information.