Analysis of Ten Typical Cases from the Guangzhou Intellectual Property Court’s “2025 White Paper on the Adjudication of Technology-Related Cases”
Published 27 February 2026
Sarah Xuan
On February 4, 2026, the Guangzhou Intellectual Property Court released the 2025 White Paper on the Adjudication of Technology-Related Cases and the “Typical Cases Serving and Safeguarding Scientific and Technological Innovation”. The release systematically summarized the court’s adjudication of technology-related cases in 2025 and featured ten cases of significance as exemplary rules. These cases cover multiple fields, including marine engineering, microbial patents, global licensing disputes over Standard Essential Patents (SEPs), medical devices and prior art defenses, ownership of service inventions, boundaries of patents with numerical features, new plant varieties, enterprise data as trade secrets, punitive damages for repetitive and malicious infringement, and the ascertainment of technical facts in platform content identification and interception technology.
The following is an introduction to the ten typical cases.
I. Technical Secret Infringement Case Concerning “Subsea Pipeline Installation Method”: Holistic Determination of the Secrecy of Marine Engineering Methods and Punitive Damages for Intentional Disclosure This case centers on a subsea pipeline installation method formed during cooperation on an overseas engineering project. According to the facts, during the cooperation between Company P and Company Z on the KOT Oil Terminal Project at the Port of Mombasa, Kenya, a “Multi-pipeline Subsea Oil Pipe Overall Towing and Installation Method” was developed based on the specific marine construction environment. Under the contractual relationship, Company P provided technical materials such as drawings and instructions to Company Z, which was bound by a corresponding confidentiality obligation. After the project was delivered, Company Z applied for an invention patent for the relevant technical solution and participated in engineering method selections and competitions with affiliated entities, winning awards. This triggered a dispute over technical secret infringement. The Guangzhou Intellectual Property Court found in the first instance that the method constituted a complete set of marine construction technical solutions and qualified as a technical secret. Company Z breached its confidentiality obligation and disclosed the involved information through public selection processes. The relevant entities constituted joint infringement with intentional and serious circumstances. Consequently, the court applied two-fold punitive damages and ordered the cessation of infringement and joint and several liability for 6 million RMB in compensation (currently under second-instance review).
The key points of adjudication in this case are reflected in at least three dimensions. First, the court did not mechanically deconstruct the engineering method into several scattered technical points. Instead, it evaluated its secrecy and value as a “complete technical solution” in conjunction with the specific engineering environment and construction process. This holistic determination approach is particularly applicable to engineering methods, procedural technologies, and systemic solution-based achievements. Second, the court identified “applying for a patent + participating in public selections and disclosing technical information” as key factual acts of breaching confidentiality obligations, highlighting that protection of technical secrets is not limited to “misappropriation” but also strictly regulates active public disclosure. Third, the court applied punitive damages within the framework of joint infringement, sending a clear signal of strong protection for key core technologies, especially for innovative achievements in the context of private enterprises’ “going global” collaborations.
From an analytical perspective, the value of this case lies not only in the individual judgment result but also in providing a negative example for enterprises dealing with the governance proposition of “whether engineering technical achievements should follow the patent route or the secret route”. In overseas engineering cooperation scenarios, technical materials circulate frequently, participants are diverse, and there is a strong demand for public display, making these areas high-risk zones for technical secrets. Through a comprehensive evaluation of contractual confidentiality obligations, public award participation, and subsequent patent application acts, the court effectively promoted the establishment of full-chain compliance mechanisms for enterprises in stages such as project initiation, technical delivery, achievement declaration, and award participation. This rule-based approach has direct reference significance for industries such as marine engineering, infrastructure “going global”, and installation methods for large-scale equipment.
II. Invention Patent Infringement Case Concerning “Pure White Shimeji Mushroom Strain”: Selection of Appraisal Methods and Interpretation of Sequence Differences in Microbial Patent Infringement This case involves the infringement of a microbial strain patent. Company F obtained an invention patent for its bred strain “Pure White Shimeji Finc-W-247” and claimed that the white jade mushrooms produced and sold by the defendant infringed its patent rights. The focus of the dispute was whether the accused strain fell within the scope of patent protection, particularly how to make a legal judgment when minor differences existed in gene detection results. During the trial, the Guangzhou Intellectual Property Court clarified that as Shimeji mushrooms are microbial strains, the specific gene fragments of the patented strain should serve as the core detection indicators, combined with morphological and ITS sequence analysis for comprehensive determination. Appraisal results showed that the consistency between the accused strain and the involved patent in a 975bp DNA fragment was greater than 99.69%. Although 1–3 base differences appeared during multiple rounds of sequencing, these difference sites were identified as low-probability errors caused by detection technology after repeated verification. Accordingly, the first instance found infringement and awarded 1 million RMB in damages; the judgment was subsequently upheld by the Supreme People’s Court in the second instance.
The most noteworthy aspect of this case is that the court did not conduct a “mechanical comparison” of biotechnology detection results but instead embedded scientific methodology into the structure of infringement determination. First, the court emphasized that microbial strain identification should account for specific gene fragments, ITS detection, and morphological observation, reflecting a “cross-verification of multiple evidence sources” approach to avoid determinism based on a single indicator. Second, the court recognized the objective possibility of errors in sequencing technology and required explanation and repeated verification of differences, thereby distinguishing “data differences” from “substantive technical differences”. Third, at the judicial level, the case addressed the legal evaluation of inconsistent SCAR molecular sequence detection results, establishing a more operable path for fact-finding in highly specialized cases such as those involving microorganisms, germplasm resources, and strain patents.
From an analytical view, this case reflects the improved adaptability of intellectual property justice to life science cases. Traditional patent infringement comparison methods are relatively mature in mechanical and electrical fields, but significant differences exist in evidence forms, technical errors, and sample stability in the fields of microorganisms and biomedicine. The court’s approach helps avoid two biases: first, the failure of rights protection due to an excessive pursuit of “complete consistency”; and second, the undue expansion of rights due to ignoring the boundaries of scientific uncertainty. For biological enterprises, this case also serves as a reminder to prepare reproducible and explainable appraisal plans and technical expert opinions early in the patent layout and enforcement stages.
III. Global Settlement of a Series of Mutual Litigation Disputes over Standard Essential Patents (SEPs) in the Field of Wireless Communication: Promoting Mediation through Adjudication, Combining Adjudication with Mediation, and Global Licensing Ecosystem Governance This series of cases centers on a licensing dispute over 4G/5G Standard Essential Patents between two leading companies in the telecommunications and chip sectors. After long-term negotiations over licensing rates and implementation failed, the parties initiated patent infringement, anti-monopoly, and rate dispute litigations in multiple jurisdictions, including China, the United Kingdom, Brazil, Germany, and the Unified Patent Court, totaling dozens of globally related cases; several municipal courts in China were also involved. After accepting five series of lawsuits involving SEP invention patent infringement, the Guangzhou Intellectual Property Court adopted a parallel plan of “advancing judicial procedures quickly and fairly + organizing substantive mediation throughout the process”. During the negotiation deadlock, the court organized industrial seminars and introduced perspectives from mobile terminal manufacturers and chip manufacturers to provide a commercially viable settlement path for both parties. Ultimately, in October 2025, the two parties reached a global “one-package” mutual licensing confidentiality agreement and withdrew their global litigations.
The significance of this case lies in the court not viewing it merely as an ordinary patent infringement dispute, but accurately identifying its composite attributes as a “contest over licensing models, ecosystem governance, and global judicial coordination”. SEP cases typically involve cross-jurisdictional, cross-industry chain, and cross-regulatory issues (the intersection of patent law and competition law). Relying solely on the rhythm of a single-case judgment often makes it difficult to achieve substantive conflict resolution. In this case, the Guangzhou Intellectual Property Court demonstrated strong procedural governance capabilities: on one hand, maintaining judicial pressure and procedural certainty by advancing the trial; on the other hand, facilitating the restart of commercial negotiations through substantive mediation design, creating a linkage between “trial progress, negotiation motivation, and industrial feedback”.
From an analytical perspective, this case provides landmark inspiration for Chinese courts participating in global intellectual property governance. Its core does not lie in the court replacing the market to determine rates, but in the court’s ability to provide a credible, professional, and enforceable procedural platform for complex global licensing disputes, driving all parties to reach commercial solutions within a rule-of-law framework. This capability is of practical significance for attracting multinational SEP disputes to seek resolution in China and enhancing China’s institutional voice in global technical governance. Simultaneously, it should be noted that such cases rely heavily on the judicial team’s comprehensive grasp of the industry ecosystem, technical standards, negotiation structures, and international litigation strategies. Whether a replicable mechanism can be formed in the future remains dependent on the accumulation of more cases.
IV. Invention Patent Infringement Case Concerning “Compressed Negative Pressure Vacuum System”: Comprehensive Determination of Medical Device Registration Succession and Prior Art Defense This case involves patent infringement and a prior art defense in the pharmaceutical and medical device sectors. Company M claimed that its invention patent for a “Compressed Negative Pressure Vacuum System” was infringed and used its registered product (the “New Certificate”) as the basis for the patented product. The defendant argued that the accused technical solution had been disclosed prior to the patent application date and belonged to the prior art. During the trial, the court conducted a comprehensive review in conjunction with medical device regulatory rules. It held that the products under the New Certificate and the “Old Certificate” were essentially the same product, as only the name had changed while the structure, composition, and scope of application remained identical. Simultaneously, relevant research papers recorded that the experimental materials were the Old Certificate products purchased from Company M. The approval date of the Old Certificate and the trademark registration date both preceded the patent application date. Furthermore, clinical cooperation agreements between Company M and hospitals showed that the Old Certificate products had been used clinically two years before the application date, and the content and term of the confidentiality clauses in the agreements were “none”. Accordingly, the court determined that the Old Certificate products constituted public use and the accused technical solution belonged to the prior art, thereby dismissing the plaintiff’s claims (currently under second-instance review).
The adjudication method in this case has strong reference value. The court did not rely solely on patent literature comparison but integrated multi-source evidence—including administrative registration information, academic papers, clinical use facts, and contractual confidentiality clauses—into a chain to construct a three-step judgment structure: “medical device product identity—disclosure by use—confidentiality status”. Especially in the determination that the “New Certificate succeeded the Old Certificate without substantive change”, the court introduced the product registration logic from the administrative regulatory system into the patent infringement judgment, demonstrating strong cross-institutional evidence interpretation capabilities.
From an analytical view, this case serves as an important warning to pharmaceutical and medical device enterprises: technical disclosure does not only occur during paper publication or exhibition displays; clinical use, disclosure of registration information, and the lack of confidentiality clauses in cooperation agreements may all undermine the stability of rights in subsequent patent enforcement. On the other hand, this case also helps prevent market entities from using “subsequent patenting” to re-include publicly used technologies within an exclusionary scope, thereby maintaining the fundamental function of the patent system to encourage genuine innovation and oppose improper monopolies.
V. Series of Patent Ownership Cases Concerning “Laser Printer Motors”: Holistic and Temporal Grasp of “Relevance” Review for Service Inventions This case focuses on ownership disputes over service inventions. Company A claimed that its former employee established affiliated companies during their tenure and used core technical information and material and technical conditions mastered at the original unit to apply for seven utility model patents in the name of external companies. Furthermore, some application dates fell within the period of employment or within one year of resignation. Company A argued these constituted service inventions and the patent rights should belong to the original unit. The defendant countered that the seven patents involved different fields and that the original unit had not conducted related patent research and development. Upon trial, the court held that the seven patents all involved important components of laser printer motors or production equipment necessary for the assembly process; they were closely related and should be viewed holistically. Meanwhile, the technical solutions were highly correlated with the employee’s duties and technical field at the original unit, and the employee had access to non-public information such as customer needs, problems, and solutions. Therefore, the court determined that these were inventions made in the performance of the unit’s tasks or primarily by using the material and technical conditions of the unit. The first-instance judgment awarded ownership of the seven patents to Company A, which was later upheld by the Guangdong High People’s Court in the second instance.
The prominent highlight of this case is that the court avoided fragmented and formalistic review in determining “relevance”. In practice, common points of contention in service invention disputes are whether different patent names, structural details, or application entities can negate the correlation with the original unit’s business. This case provided a negative answer. The court instead made its judgment based on substantive factors such as the position in the technical chain, the role in production processes, the scope of employee duties and contact, and the accessibility of non-public information, reflecting an “overall technical ecosystem perspective” in its adjudication method. In particular, observing the seven patents as a collective series effectively prevented the evasion of service invention rules through split applications or switching entities.
From an analytical perspective, this case achieves a good balance between protecting unit interests and promoting innovation through talent mobility. The case notes that “the determination of relevance for current employees can be appropriately broader than for resigned personnel”, which essentially calibrates proof standards and interest weighing across different time states. This judicial reasoning is commendable, but care must be taken in subsequent similar cases to avoid excessive expansion that might improperly inhibit the normal entrepreneurship of resigned personnel. For enterprises, this case also suggests solidifying the evidentiary basis for future ownership disputes through job descriptions, R&D project records, and technical document permission management.
VI. Invention Patent Infringement Case Concerning “Vacuum Suction Cup”: Numerical Range Limiting Technical Features and Strict Application of the Doctrine of Equivalents The dispute in this case centered on whether numerical range features in patent claims could cover an accused technical solution outside that range through the Doctrine of Equivalents (DOE). Claim 1 of the patent-in-suit limited the $H/D$ value to $0.05 \le H/D \le 0.10$. Through three scans, digital modeling, and measurements, the court confirmed that the $H/D$ value of the accused product was approximately 0.11, exceeding the upper limit of 0.10 by about 0.01. The plaintiff argued this constituted an equivalent technical feature. The Guangzhou Intellectual Property Court held that for technical features limited by numerical values or continuous numerical ranges, the DOE is not absolutely excluded; however, based on the public notice function of claims and to safeguard public interests, its application should be strictly limited. According to the description, the numerical limitation was one of the inventive points, and the patent had already appropriately expanded and reserved reasonable space for the optimal experimental range when determining the scope of protection. Therefore, the accused product’s exceedance of the upper limit was not a reasonable error and significantly exceeded the limited range, failing to constitute an equivalent. After the first instance dismissed the lawsuit, neither party appealed, and the judgment took effect.
The importance of this case lies in its clear expression regarding the “boundaries of numerical patents”. For a long time, there has been no simple answer in practice as to whether numerical ranges apply the DOE: total denial makes protection rigid, while excessive application leads to blurred boundaries. The path provided by this case is “applicable in principle, but subject to strict review”, proposing several key considerations, including: whether the value is an inventive point, whether the description specifically emphasizes the role of the value, whether the claim scope already includes a reasonable margin, and whether the deviation of the accused solution from the boundary value is significant. This move both maintains the patent’s public notice function and leaves room for the court to make substantive judgments on technical differences in individual cases.
From an analytical standpoint, this case has direct implications for both R&D and patent drafting. Patent applicants should more clearly present the technical contribution and experimental basis of numerical ranges when drafting descriptions and claims; otherwise, it may be difficult to claim coverage beyond the boundaries in subsequent enforcement. Conversely, market entities can obtain clearer legal expectations when performing design-arounds. Its institutional significance lies in promoting a virtuous cycle of “lawful bypassing—re-innovation—competition” through clarified boundaries.
VII. New Plant Variety Infringement Case Concerning “Jumou Amethyst” Phalaenopsis: Name Identification Elements and Shifting of the Burden of Proof in Variety Identity Determination This case involves one of the most core and difficult issues in new plant variety rights infringement—the determination of variety identity. The right holder claimed that the “Amethyst” Phalaenopsis produced, bred, and sold by the defendant was the same as or a similar variety to the authorized variety “Jumou Amethyst”, constituting infringement. The defendant argued that the two were not identical. After confirming that the defendant had performed acts of production, breeding, and sale, the court made a comprehensive judgment on the identity issue. Considering that several of the right holder’s new plant varieties used the enterprise trade name “Jumou” as a prefix, the core distinctive identification element in “Jumou Amethyst” was “Amethyst”. The accused variety was using this identification element, and no other authorized variety in the same genus was named as such. Furthermore, the right holder had completed the preliminary burden of proof regarding identity, while the defendant failed to provide rebuttal evidence. The court determined that the evidence on record formed a complete chain sufficient to prove a high probability of identity between the two and ruled that infringement was constituted. After the first instance, both parties appealed, and the Supreme People’s Court upheld the original judgment in the second instance.
The contribution of this case to the rules is mainly reflected in two aspects. First, while respecting scientific appraisal standards for plant varieties, the court included “core identification elements with distinctiveness in the name” as an important factor in identity determination. This expanded the application scenarios of the judicial interpretation regarding the presumption of identity for identical names, making the judgment more aligned with the reality of variety trading and market identification. Second, the court reasonably applied the rules for shifting the burden of proof and factual presumptions. It acknowledged the practical difficulties right holders generally face in obtaining breeding materials and conducting appraisals in new plant variety cases. After the right holder completed preliminary proof, the defendant was required to bear the corresponding burden of providing counter-evidence, which helps alleviate the failure of protection caused by “impossibility of proof”.
From an analytical view, this case reflects the development of judicial protection for new plant varieties from “appraisal-only determinism” toward “scientific judgment + synergy of evidence law rules”. Of course, this does not mean that name similarity automatically presumes infringement, but emphasizes that name identification elements can serve as important factual clues within a specific evidence system. For seed enterprises, standardizing naming systems, retaining evidence of the promotion and transaction of authorized varieties, and strengthening records of breeding material circulation will become key to the success or failure of future rights enforcement.
VIII. Technical Secret Infringement Case Concerning “Electronic Data of Car Seat Cover Layout Drawings”: Detailed Unfolding of the Protection Path for Enterprise Data as Trade Secrets This is a representative case of enterprise data as a subject matter of trade secret protection. Company C claimed that its “electronic data of car seat cover layout drawings” was stolen by a former employee and resold to Company Y. The latter purchased the data without verifying the source or authorization and used it in combination with its own data to produce car seat covers. Company C first complained to the market regulatory authorities, leading to administrative punishment, and then filed a technical secret infringement lawsuit. The court held that the involved electronic data contained various car seat cover layout drawings and process splicing diagrams, which were not obtainable simply through public channels. The data possessed secrecy and commercial value, and the right holder had taken corresponding confidentiality measures, thus constituting a technical secret. Combined with the facts of the administrative punishment and evidence in this case, the court determined that the accused data was substantially identical to the right holder’s technical secret and that the defendants constituted joint infringement. The first instance awarded more than 260,000 RMB in damages, which was subsequently upheld by the Guangdong High People’s Court in the second instance.
The key point of adjudication in this case is that the court performed content layering and characterization of the “data” rather than abstractly discussing “whether data can be protected by trade secrets”. In practice, enterprise data often mixes public information, processed and organized information, model parameters, drawing data, process rules, and customer preferences. In this case, the court emphasized that different contents and their natures should be distinguished before determining whether they meet the requirements of secrecy, value, and confidentiality; this method is clearly superior to generalized judgment. Another key point is that the court clarified that “providing licensing services externally does not necessarily mean the data is public”, responding to the tension between the commercial utilization of data and the maintenance of secrecy in digital economy scenarios.
From an analytical perspective, this case can be seen as a “practical case” in the construction of basic systems for the judicial protection of data interests. Its contribution lies not in creating a brand-new right, but in providing an operable protection scheme for data self-built, self-collected, and self-used by enterprises through the path of trade secret law. This is of particular practical value for enterprises in the digital transformation of manufacturing: many high-value data points are not the algorithms themselves but production data assets deeply coupled with processes, layouts, parameters, and flows. If enterprises wish to obtain judicial support, in addition to taking confidentiality measures such as permission control, resignation management, and access logs, they must also clearly define the formation methods and commercial value of different data sets in daily operations to facilitate refined proof in litigation.
IX. Invention Patent Infringement Case Concerning “Fluid Safety Interrupter”: “Relay-style” Infringement by Affiliated Enterprises and the Reference Determination of the Base for Punitive Damages This is an important case for applying punitive damages to combat repetitive, continuous, and evasive infringement. The right holder and the defendant in a prior case had reached a mediation agreement regarding the same invention patent infringement dispute during the second instance, agreeing on compensation of 600,000 RMB. Subsequently, the right holder discovered that a new accused subject was highly correlated with the prior subject in terms of controlling shareholders, receiving accounts, business addresses, and product similarity. The right holder argued that the actual controller, despite knowing of the infringement, continued to implement it through different affiliated enterprises, constituting joint intentional infringement, and requested the application of 5-fold punitive damages. The Guangzhou Intellectual Property Court found that the actual controller’s intent to infringe was continuous and the behavior lasted for a long time, constituting intentional infringement with serious circumstances, and thus punitive damages should apply. When losses or profits could not be accurately calculated and there was no royalty for reference, the mediation agreement amount from the prior case could serve as a reference base for punitive damages. Applying 2-fold punitive damages, the court ultimately awarded 1.8 million RMB in compensation. The parties settled during the second instance.
The most enlightening aspect of this case is the handling of “whether the prior mediation amount can serve as the base for calculating punitive damages in a subsequent case”. Generally, mediation amounts involve both concessions and mutual consent, and their direct use in subsequent calculations may trigger controversy. However, in this case, the court did not apply it mechanically. Instead, based on the correlation of the infringing subjects, the similarity of the infringing circumstances, and the evidentiary dilemma where losses/profits were difficult to ascertain, it used the amount as a reference base under specific conditions. This treatment both enhances the operability of punitive damages and prevents infringers from frustrating strict protection through entity switching or account evasion.
From an analytical view, this case has a strong deterrent effect on “rotating infringement by affiliated enterprises” and “behind-the-scenes manipulation by actual controllers”. In IP infringement practice, once an infringer forms a pattern of “continuing infringement by changing affiliated subjects”, ordinary compensation often fails to achieve a deterrent function. By identifying the continuity of the actual controller’s behavior and increasing the cost of infringement, this case strengthens the institutional purpose of the punitive damages system. Of course, at the specific application level, one should still insist on sufficient evidence, clear related facts, and explicit subjective malice to avoid over-inference regarding normal corporate structural arrangements.
X. Fact-Finding Case for Short Video Content Identification and Interception Technology Using the “Three-Step Comparison Method”: The Empirical Shift of the Technical Investigator System and In-Court Testing Although this case originated from copyright infringement and unfair competition disputes, its typical significance is mainly reflected in the innovation of technical fact-finding methods. Company T claimed that platforms operated by Company K and Company L contained over 140,000 video segments substantially similar to its works, and requested the platforms to delete, filter, and intercept infringing videos and pay massive damages. During litigation, the core dispute became “whether the platforms possess the technical feasibility to effectively identify, filter, and intercept massive amounts of allegedly infringing videos”, with both sides holding conflicting views. With the involvement of technical investigators, the Guangzhou Intellectual Property Court organized technical inspections and designed a “three-step comparison method” testing plan for the dispute: first, testing both platforms with videos close to the original master; second, randomly capturing and testing suspected infringing videos circulating on the network; and third, directly testing other infringing videos on an evidence preservation platform, followed by a comprehensive analysis of identification rates and interception probabilities. The testing results showed that possessing the original master is a necessary condition for a high identification rate, but not a sufficient one; factors such as content position also significantly affect identification results. Technical investigators provided professional opinions based on these results, which were adopted by the collegial bench. The case is currently in the second-instance stage.
The value of this case lies first in the methodological breakthrough: advancing disputes over platform algorithms/identification capabilities from “contests of paper-based claims and expert opinions” to “verifiable empirical data in a courtroom scenario”, achieving a shift in technical fact determination from indirect inference to objective empiricism. Second, the court did not attempt to reach an abstract conclusion of “the platform certainly can/cannot intercept”; instead, through step-by-step testing, it revealed multiple technical variables affecting identification and interception, forming a judicial understanding more aligned with industrial reality. Third, technical investigators in this case did not merely “explain technology” but substantively participated in the design of the investigation plan, the organization of tests, and the interpretation of results, fully reflecting the procedural value of the technical investigator system in complex digital cases.
From an analytical perspective, this case is instructive for future disputes involving AI recognition, content auditing, and recommendation systems. As algorithmic capability becomes an important basis for judging the boundaries of platform responsibility, how courts ascertain “whether it is technically feasible”, “at what cost it is feasible”, and “under what conditions it is feasible” will become increasingly critical. The combination of “Technical Investigator + In-Court Testing” provides a promising path for this. Of course, issues such as sample selection, neutrality control, and the reproducibility of results in such tests also need to be further standardized in subsequent practice to enhance consistency and predictability in similar cases.
Comment Viewed as a whole, the ten typical cases released by the Guangzhou Intellectual Property Court this time represent an intentional summary of adjudicatory rules and fact-finding methods that are transmissible, referable, and replicable across different technical scenarios. Together, these cases demonstrate that judgments in technology-related intellectual property matters are not only final arbiters of disputes but also shapers of rules for the order of innovation and judicial coordinators of the industrial ecosystem.
For the academic and legal communities, this batch of cases reminds us to understand intellectual property adjudication through a trinity of “technical facts—industrial background—institutional objectives”, thereby establishing a dynamic coordination between strict protection, the balance of interests, and rule-based leadership, allowing intellectual property justice to become the legal support for the development of new quality productive forces.
The following is an introduction to the ten typical cases.
I. Technical Secret Infringement Case Concerning “Subsea Pipeline Installation Method”: Holistic Determination of the Secrecy of Marine Engineering Methods and Punitive Damages for Intentional Disclosure This case centers on a subsea pipeline installation method formed during cooperation on an overseas engineering project. According to the facts, during the cooperation between Company P and Company Z on the KOT Oil Terminal Project at the Port of Mombasa, Kenya, a “Multi-pipeline Subsea Oil Pipe Overall Towing and Installation Method” was developed based on the specific marine construction environment. Under the contractual relationship, Company P provided technical materials such as drawings and instructions to Company Z, which was bound by a corresponding confidentiality obligation. After the project was delivered, Company Z applied for an invention patent for the relevant technical solution and participated in engineering method selections and competitions with affiliated entities, winning awards. This triggered a dispute over technical secret infringement. The Guangzhou Intellectual Property Court found in the first instance that the method constituted a complete set of marine construction technical solutions and qualified as a technical secret. Company Z breached its confidentiality obligation and disclosed the involved information through public selection processes. The relevant entities constituted joint infringement with intentional and serious circumstances. Consequently, the court applied two-fold punitive damages and ordered the cessation of infringement and joint and several liability for 6 million RMB in compensation (currently under second-instance review).
The key points of adjudication in this case are reflected in at least three dimensions. First, the court did not mechanically deconstruct the engineering method into several scattered technical points. Instead, it evaluated its secrecy and value as a “complete technical solution” in conjunction with the specific engineering environment and construction process. This holistic determination approach is particularly applicable to engineering methods, procedural technologies, and systemic solution-based achievements. Second, the court identified “applying for a patent + participating in public selections and disclosing technical information” as key factual acts of breaching confidentiality obligations, highlighting that protection of technical secrets is not limited to “misappropriation” but also strictly regulates active public disclosure. Third, the court applied punitive damages within the framework of joint infringement, sending a clear signal of strong protection for key core technologies, especially for innovative achievements in the context of private enterprises’ “going global” collaborations.
From an analytical perspective, the value of this case lies not only in the individual judgment result but also in providing a negative example for enterprises dealing with the governance proposition of “whether engineering technical achievements should follow the patent route or the secret route”. In overseas engineering cooperation scenarios, technical materials circulate frequently, participants are diverse, and there is a strong demand for public display, making these areas high-risk zones for technical secrets. Through a comprehensive evaluation of contractual confidentiality obligations, public award participation, and subsequent patent application acts, the court effectively promoted the establishment of full-chain compliance mechanisms for enterprises in stages such as project initiation, technical delivery, achievement declaration, and award participation. This rule-based approach has direct reference significance for industries such as marine engineering, infrastructure “going global”, and installation methods for large-scale equipment.
II. Invention Patent Infringement Case Concerning “Pure White Shimeji Mushroom Strain”: Selection of Appraisal Methods and Interpretation of Sequence Differences in Microbial Patent Infringement This case involves the infringement of a microbial strain patent. Company F obtained an invention patent for its bred strain “Pure White Shimeji Finc-W-247” and claimed that the white jade mushrooms produced and sold by the defendant infringed its patent rights. The focus of the dispute was whether the accused strain fell within the scope of patent protection, particularly how to make a legal judgment when minor differences existed in gene detection results. During the trial, the Guangzhou Intellectual Property Court clarified that as Shimeji mushrooms are microbial strains, the specific gene fragments of the patented strain should serve as the core detection indicators, combined with morphological and ITS sequence analysis for comprehensive determination. Appraisal results showed that the consistency between the accused strain and the involved patent in a 975bp DNA fragment was greater than 99.69%. Although 1–3 base differences appeared during multiple rounds of sequencing, these difference sites were identified as low-probability errors caused by detection technology after repeated verification. Accordingly, the first instance found infringement and awarded 1 million RMB in damages; the judgment was subsequently upheld by the Supreme People’s Court in the second instance.
The most noteworthy aspect of this case is that the court did not conduct a “mechanical comparison” of biotechnology detection results but instead embedded scientific methodology into the structure of infringement determination. First, the court emphasized that microbial strain identification should account for specific gene fragments, ITS detection, and morphological observation, reflecting a “cross-verification of multiple evidence sources” approach to avoid determinism based on a single indicator. Second, the court recognized the objective possibility of errors in sequencing technology and required explanation and repeated verification of differences, thereby distinguishing “data differences” from “substantive technical differences”. Third, at the judicial level, the case addressed the legal evaluation of inconsistent SCAR molecular sequence detection results, establishing a more operable path for fact-finding in highly specialized cases such as those involving microorganisms, germplasm resources, and strain patents.
From an analytical view, this case reflects the improved adaptability of intellectual property justice to life science cases. Traditional patent infringement comparison methods are relatively mature in mechanical and electrical fields, but significant differences exist in evidence forms, technical errors, and sample stability in the fields of microorganisms and biomedicine. The court’s approach helps avoid two biases: first, the failure of rights protection due to an excessive pursuit of “complete consistency”; and second, the undue expansion of rights due to ignoring the boundaries of scientific uncertainty. For biological enterprises, this case also serves as a reminder to prepare reproducible and explainable appraisal plans and technical expert opinions early in the patent layout and enforcement stages.
III. Global Settlement of a Series of Mutual Litigation Disputes over Standard Essential Patents (SEPs) in the Field of Wireless Communication: Promoting Mediation through Adjudication, Combining Adjudication with Mediation, and Global Licensing Ecosystem Governance This series of cases centers on a licensing dispute over 4G/5G Standard Essential Patents between two leading companies in the telecommunications and chip sectors. After long-term negotiations over licensing rates and implementation failed, the parties initiated patent infringement, anti-monopoly, and rate dispute litigations in multiple jurisdictions, including China, the United Kingdom, Brazil, Germany, and the Unified Patent Court, totaling dozens of globally related cases; several municipal courts in China were also involved. After accepting five series of lawsuits involving SEP invention patent infringement, the Guangzhou Intellectual Property Court adopted a parallel plan of “advancing judicial procedures quickly and fairly + organizing substantive mediation throughout the process”. During the negotiation deadlock, the court organized industrial seminars and introduced perspectives from mobile terminal manufacturers and chip manufacturers to provide a commercially viable settlement path for both parties. Ultimately, in October 2025, the two parties reached a global “one-package” mutual licensing confidentiality agreement and withdrew their global litigations.
The significance of this case lies in the court not viewing it merely as an ordinary patent infringement dispute, but accurately identifying its composite attributes as a “contest over licensing models, ecosystem governance, and global judicial coordination”. SEP cases typically involve cross-jurisdictional, cross-industry chain, and cross-regulatory issues (the intersection of patent law and competition law). Relying solely on the rhythm of a single-case judgment often makes it difficult to achieve substantive conflict resolution. In this case, the Guangzhou Intellectual Property Court demonstrated strong procedural governance capabilities: on one hand, maintaining judicial pressure and procedural certainty by advancing the trial; on the other hand, facilitating the restart of commercial negotiations through substantive mediation design, creating a linkage between “trial progress, negotiation motivation, and industrial feedback”.
From an analytical perspective, this case provides landmark inspiration for Chinese courts participating in global intellectual property governance. Its core does not lie in the court replacing the market to determine rates, but in the court’s ability to provide a credible, professional, and enforceable procedural platform for complex global licensing disputes, driving all parties to reach commercial solutions within a rule-of-law framework. This capability is of practical significance for attracting multinational SEP disputes to seek resolution in China and enhancing China’s institutional voice in global technical governance. Simultaneously, it should be noted that such cases rely heavily on the judicial team’s comprehensive grasp of the industry ecosystem, technical standards, negotiation structures, and international litigation strategies. Whether a replicable mechanism can be formed in the future remains dependent on the accumulation of more cases.
IV. Invention Patent Infringement Case Concerning “Compressed Negative Pressure Vacuum System”: Comprehensive Determination of Medical Device Registration Succession and Prior Art Defense This case involves patent infringement and a prior art defense in the pharmaceutical and medical device sectors. Company M claimed that its invention patent for a “Compressed Negative Pressure Vacuum System” was infringed and used its registered product (the “New Certificate”) as the basis for the patented product. The defendant argued that the accused technical solution had been disclosed prior to the patent application date and belonged to the prior art. During the trial, the court conducted a comprehensive review in conjunction with medical device regulatory rules. It held that the products under the New Certificate and the “Old Certificate” were essentially the same product, as only the name had changed while the structure, composition, and scope of application remained identical. Simultaneously, relevant research papers recorded that the experimental materials were the Old Certificate products purchased from Company M. The approval date of the Old Certificate and the trademark registration date both preceded the patent application date. Furthermore, clinical cooperation agreements between Company M and hospitals showed that the Old Certificate products had been used clinically two years before the application date, and the content and term of the confidentiality clauses in the agreements were “none”. Accordingly, the court determined that the Old Certificate products constituted public use and the accused technical solution belonged to the prior art, thereby dismissing the plaintiff’s claims (currently under second-instance review).
The adjudication method in this case has strong reference value. The court did not rely solely on patent literature comparison but integrated multi-source evidence—including administrative registration information, academic papers, clinical use facts, and contractual confidentiality clauses—into a chain to construct a three-step judgment structure: “medical device product identity—disclosure by use—confidentiality status”. Especially in the determination that the “New Certificate succeeded the Old Certificate without substantive change”, the court introduced the product registration logic from the administrative regulatory system into the patent infringement judgment, demonstrating strong cross-institutional evidence interpretation capabilities.
From an analytical view, this case serves as an important warning to pharmaceutical and medical device enterprises: technical disclosure does not only occur during paper publication or exhibition displays; clinical use, disclosure of registration information, and the lack of confidentiality clauses in cooperation agreements may all undermine the stability of rights in subsequent patent enforcement. On the other hand, this case also helps prevent market entities from using “subsequent patenting” to re-include publicly used technologies within an exclusionary scope, thereby maintaining the fundamental function of the patent system to encourage genuine innovation and oppose improper monopolies.
V. Series of Patent Ownership Cases Concerning “Laser Printer Motors”: Holistic and Temporal Grasp of “Relevance” Review for Service Inventions This case focuses on ownership disputes over service inventions. Company A claimed that its former employee established affiliated companies during their tenure and used core technical information and material and technical conditions mastered at the original unit to apply for seven utility model patents in the name of external companies. Furthermore, some application dates fell within the period of employment or within one year of resignation. Company A argued these constituted service inventions and the patent rights should belong to the original unit. The defendant countered that the seven patents involved different fields and that the original unit had not conducted related patent research and development. Upon trial, the court held that the seven patents all involved important components of laser printer motors or production equipment necessary for the assembly process; they were closely related and should be viewed holistically. Meanwhile, the technical solutions were highly correlated with the employee’s duties and technical field at the original unit, and the employee had access to non-public information such as customer needs, problems, and solutions. Therefore, the court determined that these were inventions made in the performance of the unit’s tasks or primarily by using the material and technical conditions of the unit. The first-instance judgment awarded ownership of the seven patents to Company A, which was later upheld by the Guangdong High People’s Court in the second instance.
The prominent highlight of this case is that the court avoided fragmented and formalistic review in determining “relevance”. In practice, common points of contention in service invention disputes are whether different patent names, structural details, or application entities can negate the correlation with the original unit’s business. This case provided a negative answer. The court instead made its judgment based on substantive factors such as the position in the technical chain, the role in production processes, the scope of employee duties and contact, and the accessibility of non-public information, reflecting an “overall technical ecosystem perspective” in its adjudication method. In particular, observing the seven patents as a collective series effectively prevented the evasion of service invention rules through split applications or switching entities.
From an analytical perspective, this case achieves a good balance between protecting unit interests and promoting innovation through talent mobility. The case notes that “the determination of relevance for current employees can be appropriately broader than for resigned personnel”, which essentially calibrates proof standards and interest weighing across different time states. This judicial reasoning is commendable, but care must be taken in subsequent similar cases to avoid excessive expansion that might improperly inhibit the normal entrepreneurship of resigned personnel. For enterprises, this case also suggests solidifying the evidentiary basis for future ownership disputes through job descriptions, R&D project records, and technical document permission management.
VI. Invention Patent Infringement Case Concerning “Vacuum Suction Cup”: Numerical Range Limiting Technical Features and Strict Application of the Doctrine of Equivalents The dispute in this case centered on whether numerical range features in patent claims could cover an accused technical solution outside that range through the Doctrine of Equivalents (DOE). Claim 1 of the patent-in-suit limited the $H/D$ value to $0.05 \le H/D \le 0.10$. Through three scans, digital modeling, and measurements, the court confirmed that the $H/D$ value of the accused product was approximately 0.11, exceeding the upper limit of 0.10 by about 0.01. The plaintiff argued this constituted an equivalent technical feature. The Guangzhou Intellectual Property Court held that for technical features limited by numerical values or continuous numerical ranges, the DOE is not absolutely excluded; however, based on the public notice function of claims and to safeguard public interests, its application should be strictly limited. According to the description, the numerical limitation was one of the inventive points, and the patent had already appropriately expanded and reserved reasonable space for the optimal experimental range when determining the scope of protection. Therefore, the accused product’s exceedance of the upper limit was not a reasonable error and significantly exceeded the limited range, failing to constitute an equivalent. After the first instance dismissed the lawsuit, neither party appealed, and the judgment took effect.
The importance of this case lies in its clear expression regarding the “boundaries of numerical patents”. For a long time, there has been no simple answer in practice as to whether numerical ranges apply the DOE: total denial makes protection rigid, while excessive application leads to blurred boundaries. The path provided by this case is “applicable in principle, but subject to strict review”, proposing several key considerations, including: whether the value is an inventive point, whether the description specifically emphasizes the role of the value, whether the claim scope already includes a reasonable margin, and whether the deviation of the accused solution from the boundary value is significant. This move both maintains the patent’s public notice function and leaves room for the court to make substantive judgments on technical differences in individual cases.
From an analytical standpoint, this case has direct implications for both R&D and patent drafting. Patent applicants should more clearly present the technical contribution and experimental basis of numerical ranges when drafting descriptions and claims; otherwise, it may be difficult to claim coverage beyond the boundaries in subsequent enforcement. Conversely, market entities can obtain clearer legal expectations when performing design-arounds. Its institutional significance lies in promoting a virtuous cycle of “lawful bypassing—re-innovation—competition” through clarified boundaries.
VII. New Plant Variety Infringement Case Concerning “Jumou Amethyst” Phalaenopsis: Name Identification Elements and Shifting of the Burden of Proof in Variety Identity Determination This case involves one of the most core and difficult issues in new plant variety rights infringement—the determination of variety identity. The right holder claimed that the “Amethyst” Phalaenopsis produced, bred, and sold by the defendant was the same as or a similar variety to the authorized variety “Jumou Amethyst”, constituting infringement. The defendant argued that the two were not identical. After confirming that the defendant had performed acts of production, breeding, and sale, the court made a comprehensive judgment on the identity issue. Considering that several of the right holder’s new plant varieties used the enterprise trade name “Jumou” as a prefix, the core distinctive identification element in “Jumou Amethyst” was “Amethyst”. The accused variety was using this identification element, and no other authorized variety in the same genus was named as such. Furthermore, the right holder had completed the preliminary burden of proof regarding identity, while the defendant failed to provide rebuttal evidence. The court determined that the evidence on record formed a complete chain sufficient to prove a high probability of identity between the two and ruled that infringement was constituted. After the first instance, both parties appealed, and the Supreme People’s Court upheld the original judgment in the second instance.
The contribution of this case to the rules is mainly reflected in two aspects. First, while respecting scientific appraisal standards for plant varieties, the court included “core identification elements with distinctiveness in the name” as an important factor in identity determination. This expanded the application scenarios of the judicial interpretation regarding the presumption of identity for identical names, making the judgment more aligned with the reality of variety trading and market identification. Second, the court reasonably applied the rules for shifting the burden of proof and factual presumptions. It acknowledged the practical difficulties right holders generally face in obtaining breeding materials and conducting appraisals in new plant variety cases. After the right holder completed preliminary proof, the defendant was required to bear the corresponding burden of providing counter-evidence, which helps alleviate the failure of protection caused by “impossibility of proof”.
From an analytical view, this case reflects the development of judicial protection for new plant varieties from “appraisal-only determinism” toward “scientific judgment + synergy of evidence law rules”. Of course, this does not mean that name similarity automatically presumes infringement, but emphasizes that name identification elements can serve as important factual clues within a specific evidence system. For seed enterprises, standardizing naming systems, retaining evidence of the promotion and transaction of authorized varieties, and strengthening records of breeding material circulation will become key to the success or failure of future rights enforcement.
VIII. Technical Secret Infringement Case Concerning “Electronic Data of Car Seat Cover Layout Drawings”: Detailed Unfolding of the Protection Path for Enterprise Data as Trade Secrets This is a representative case of enterprise data as a subject matter of trade secret protection. Company C claimed that its “electronic data of car seat cover layout drawings” was stolen by a former employee and resold to Company Y. The latter purchased the data without verifying the source or authorization and used it in combination with its own data to produce car seat covers. Company C first complained to the market regulatory authorities, leading to administrative punishment, and then filed a technical secret infringement lawsuit. The court held that the involved electronic data contained various car seat cover layout drawings and process splicing diagrams, which were not obtainable simply through public channels. The data possessed secrecy and commercial value, and the right holder had taken corresponding confidentiality measures, thus constituting a technical secret. Combined with the facts of the administrative punishment and evidence in this case, the court determined that the accused data was substantially identical to the right holder’s technical secret and that the defendants constituted joint infringement. The first instance awarded more than 260,000 RMB in damages, which was subsequently upheld by the Guangdong High People’s Court in the second instance.
The key point of adjudication in this case is that the court performed content layering and characterization of the “data” rather than abstractly discussing “whether data can be protected by trade secrets”. In practice, enterprise data often mixes public information, processed and organized information, model parameters, drawing data, process rules, and customer preferences. In this case, the court emphasized that different contents and their natures should be distinguished before determining whether they meet the requirements of secrecy, value, and confidentiality; this method is clearly superior to generalized judgment. Another key point is that the court clarified that “providing licensing services externally does not necessarily mean the data is public”, responding to the tension between the commercial utilization of data and the maintenance of secrecy in digital economy scenarios.
From an analytical perspective, this case can be seen as a “practical case” in the construction of basic systems for the judicial protection of data interests. Its contribution lies not in creating a brand-new right, but in providing an operable protection scheme for data self-built, self-collected, and self-used by enterprises through the path of trade secret law. This is of particular practical value for enterprises in the digital transformation of manufacturing: many high-value data points are not the algorithms themselves but production data assets deeply coupled with processes, layouts, parameters, and flows. If enterprises wish to obtain judicial support, in addition to taking confidentiality measures such as permission control, resignation management, and access logs, they must also clearly define the formation methods and commercial value of different data sets in daily operations to facilitate refined proof in litigation.
IX. Invention Patent Infringement Case Concerning “Fluid Safety Interrupter”: “Relay-style” Infringement by Affiliated Enterprises and the Reference Determination of the Base for Punitive Damages This is an important case for applying punitive damages to combat repetitive, continuous, and evasive infringement. The right holder and the defendant in a prior case had reached a mediation agreement regarding the same invention patent infringement dispute during the second instance, agreeing on compensation of 600,000 RMB. Subsequently, the right holder discovered that a new accused subject was highly correlated with the prior subject in terms of controlling shareholders, receiving accounts, business addresses, and product similarity. The right holder argued that the actual controller, despite knowing of the infringement, continued to implement it through different affiliated enterprises, constituting joint intentional infringement, and requested the application of 5-fold punitive damages. The Guangzhou Intellectual Property Court found that the actual controller’s intent to infringe was continuous and the behavior lasted for a long time, constituting intentional infringement with serious circumstances, and thus punitive damages should apply. When losses or profits could not be accurately calculated and there was no royalty for reference, the mediation agreement amount from the prior case could serve as a reference base for punitive damages. Applying 2-fold punitive damages, the court ultimately awarded 1.8 million RMB in compensation. The parties settled during the second instance.
The most enlightening aspect of this case is the handling of “whether the prior mediation amount can serve as the base for calculating punitive damages in a subsequent case”. Generally, mediation amounts involve both concessions and mutual consent, and their direct use in subsequent calculations may trigger controversy. However, in this case, the court did not apply it mechanically. Instead, based on the correlation of the infringing subjects, the similarity of the infringing circumstances, and the evidentiary dilemma where losses/profits were difficult to ascertain, it used the amount as a reference base under specific conditions. This treatment both enhances the operability of punitive damages and prevents infringers from frustrating strict protection through entity switching or account evasion.
From an analytical view, this case has a strong deterrent effect on “rotating infringement by affiliated enterprises” and “behind-the-scenes manipulation by actual controllers”. In IP infringement practice, once an infringer forms a pattern of “continuing infringement by changing affiliated subjects”, ordinary compensation often fails to achieve a deterrent function. By identifying the continuity of the actual controller’s behavior and increasing the cost of infringement, this case strengthens the institutional purpose of the punitive damages system. Of course, at the specific application level, one should still insist on sufficient evidence, clear related facts, and explicit subjective malice to avoid over-inference regarding normal corporate structural arrangements.
X. Fact-Finding Case for Short Video Content Identification and Interception Technology Using the “Three-Step Comparison Method”: The Empirical Shift of the Technical Investigator System and In-Court Testing Although this case originated from copyright infringement and unfair competition disputes, its typical significance is mainly reflected in the innovation of technical fact-finding methods. Company T claimed that platforms operated by Company K and Company L contained over 140,000 video segments substantially similar to its works, and requested the platforms to delete, filter, and intercept infringing videos and pay massive damages. During litigation, the core dispute became “whether the platforms possess the technical feasibility to effectively identify, filter, and intercept massive amounts of allegedly infringing videos”, with both sides holding conflicting views. With the involvement of technical investigators, the Guangzhou Intellectual Property Court organized technical inspections and designed a “three-step comparison method” testing plan for the dispute: first, testing both platforms with videos close to the original master; second, randomly capturing and testing suspected infringing videos circulating on the network; and third, directly testing other infringing videos on an evidence preservation platform, followed by a comprehensive analysis of identification rates and interception probabilities. The testing results showed that possessing the original master is a necessary condition for a high identification rate, but not a sufficient one; factors such as content position also significantly affect identification results. Technical investigators provided professional opinions based on these results, which were adopted by the collegial bench. The case is currently in the second-instance stage.
The value of this case lies first in the methodological breakthrough: advancing disputes over platform algorithms/identification capabilities from “contests of paper-based claims and expert opinions” to “verifiable empirical data in a courtroom scenario”, achieving a shift in technical fact determination from indirect inference to objective empiricism. Second, the court did not attempt to reach an abstract conclusion of “the platform certainly can/cannot intercept”; instead, through step-by-step testing, it revealed multiple technical variables affecting identification and interception, forming a judicial understanding more aligned with industrial reality. Third, technical investigators in this case did not merely “explain technology” but substantively participated in the design of the investigation plan, the organization of tests, and the interpretation of results, fully reflecting the procedural value of the technical investigator system in complex digital cases.
From an analytical perspective, this case is instructive for future disputes involving AI recognition, content auditing, and recommendation systems. As algorithmic capability becomes an important basis for judging the boundaries of platform responsibility, how courts ascertain “whether it is technically feasible”, “at what cost it is feasible”, and “under what conditions it is feasible” will become increasingly critical. The combination of “Technical Investigator + In-Court Testing” provides a promising path for this. Of course, issues such as sample selection, neutrality control, and the reproducibility of results in such tests also need to be further standardized in subsequent practice to enhance consistency and predictability in similar cases.
Comment Viewed as a whole, the ten typical cases released by the Guangzhou Intellectual Property Court this time represent an intentional summary of adjudicatory rules and fact-finding methods that are transmissible, referable, and replicable across different technical scenarios. Together, these cases demonstrate that judgments in technology-related intellectual property matters are not only final arbiters of disputes but also shapers of rules for the order of innovation and judicial coordinators of the industrial ecosystem.
For the academic and legal communities, this batch of cases reminds us to understand intellectual property adjudication through a trinity of “technical facts—industrial background—institutional objectives”, thereby establishing a dynamic coordination between strict protection, the balance of interests, and rule-based leadership, allowing intellectual property justice to become the legal support for the development of new quality productive forces.