U.S. and European Automotive Updates: Installment 2

U.S. Update

I. Federal Circuit Affirms Motion to Dismiss Patent-Ineligible Claims in TJTM v. Google

In TJTM Technologies, LLC v. Google LLC, No. 2025-1218, 2026 WL 1243344 (Fed. Cir. May 5, 2026), the Federal Circuit addressed the patent-eligibility of claims directed to abstract ideas in mobile device technology. The court addressed the oft-litigated concept  that claims “directed to a technological solution to a technological problem” can be patent-eligible subject matter.

TJTM filed a complaint of patent infringement against Google asserting U.S. Patent No. 8,958,853, which generally relates to the method of mobile devices pairing with vehicles to automatically enter inactive mode. Google filed a motion to dismiss TJTM’s complaint, challenging the patent-eligibility of TJTM’s asserted claim. The district court granted Google’s motion and dismissed the case after applying the Alice two-step framework and concluding that the claim is directed to an abstract idea without substantially more.

The Federal Circuit affirmed the district court’s conclusion that TJTM’s amended complaint could not withstand Google’s patent-eligibility challenge. In step one of the Alice framework, the Federal Circuit concluded that the asserted claim was merely directed to an abstract idea of adding a communication-suppression function to a phone. The court stated that a claimed invention is an abstract idea if it “merely recites a different mode of operation for a mobile phone without reciting any change to the underlying mobile phone technology.” In the court’s view, an improvement to user experience alone is not a technological improvement. The Federal Circuit also agreed with the district court’s conclusion at Alice step two. The court determined that TJTM’s claim recites “generic and well-known” components “ordered in a conventional fashion” since it provides nothing more than “the abstract idea of suppressing notifications on a cell phone.” Again, the court stated that “merely applying an abstract idea to a ‘particular technological environment’” is not enough. Finally, the Federal Circuit warned against the use of conclusory allegations as to an inventive concept, as TJTM had done. Accordingly, the Federal Circuit determined that the claims of TJTM’s patent are patent-ineligible under 35 U.S.C. § 101.

II. Federal Circuit Reverses Preliminary Injunctive Relief in Ridge v. Kirk NationaLease 

On July 13, 2026, the Federal Circuit ruled that a district court’s grant of a preliminary injunction was an abuse of discretion in Ridge Corporation v. Kirk NationaLease Co., 181 F.4th 1224 (Fed. Cir. 2026), and reversed and remanded the case.

Ridge was the exclusive licensee of U.S. Patent No. 9,151,084, directed to an insulated overhead door designed to roll open and closed in tracks for use in the cold storage distribution industry, such as refrigerated trucks. Ridge filed an action against Kirk, alleging infringement and tortious interference with its business. The district court granted Ridge’s motion for a preliminary injunction, concluding there was a strong likelihood of success on the merits of these claims.

Regarding the infringement claims, the Federal Circuit held that the district court erred in determining that Ridge had established a likelihood of success on the merits because Kirk had shown that there is a substantial question regarding whether the accused door could satisfy three separate limitations of the asserted claim. Given the early stage of the proceedings, a conclusive determination was not required.  On appeal, Ridge attempted to point to unasserted dependent claims to bolster its claim construction. However, the Federal Circuit stated that “the language of a dependent claim cannot change the scope of an independent claim whose meaning is clear on its face.” The court also considered the specification, prosecution history, and extrinsic evidence to aid its interpretation of the claim limitations. Additionally, the Federal Circuit concluded that Ridge’s argument that it would suffer irreparable harm without an injunction was “speculative at best” because Ridge failed to show a “causal nexus” between the sales of the accused doors and the reduced prices Ridge set for its own doors. Finally, the Federal Circuit found that Ridge presented no credible evidence that the alleged tortious interference conduct was likely to recur, therefore this claim was insufficient to support the grant of injunctive relief.

European Update

III. Nokia v Geely: UPC Local Divisions Munich and Mannheim and Regional Court Munich I on SEPs Relating to Connected Cars

Overview. In the summer of 2025, Finnish telecommunication technology company Nokia opened a multi-venue campaign against Chinese automaker Geely (owner of Lynk & Co, Polestar, Lotus and others) over patents declared essential to the 4G and 5G cellular standards used in connected cars.

Parallel forum strategy. Nokia distributed four cases across three Germany-located venues simultaneously, two with the Unified Patent Court (“UPC”), Local Divisions Munich (docket no. UPC_CFI_661/2025) and Mannheim (docket no. UPC_CFI_662/2025) and the Regional Court Munich I (docket nos. 7 O 9322/25 and 21 O 9323/25).

Anti-Interim-License Injunctions again. After Geely applied for an interim license in China, Nokia countered with a so-called anti-interim-license injunction (“AILI”). In spring 2026, both the Regional Court Munich I and the UPC granted Nokia injunctions barring Geely from pursuing the Chinese interim license. At the UPC, the Local Division Mannheim threatened with penalties of up to EUR 50 million. The Regional Court Munich I issued a parallel order with penalties up to EUR 250,000.00. 

Outcome. On 21 May 2026, the day the hearing was scheduled for the Regional Court Munich I (docket no. 7 O 9322/25), the court confirmed that Nokia had withdrawn the lawsuit in question. Reporting indicates the parties have settled. What remains unclear publicly, however, is whether Geely concluded a direct bilateral licence with Nokia or instead obtained coverage through an Avanci licence. 

Why this matters. Litigation over connected cars is far from over and European courts continue to defend their jurisdiction wherever it is questioned by defendants seeking support from courts abroad.

IV. Valeo v Bosch: UPC Court of Appeal Refining Jurisdiction of The Central Division in Windscreen-Wiper Case

Overview. French automotive supplier Valeo sued German competitor Robert Bosch at the UPC over windscreen-wiper technology for cars, asserting EP 2 671 766. The case is less about the technical merits than about a landmark jurisdictional ruling by the UPC Court of Appeal that reshapes where multi-defendant actions can be brought.

Jurisdictional question. Among the six Robert Bosch entities on the defending side, two were domiciled outside UPC territory (Robert Bosch Do Beograd, located in Serbia; and Bosch Automotive Products Co., located in China). Valeo relied on Article 33(1) UPCA, which allows actions against defendants based outside the Contracting Member States to be brought before the UPC Central Division and argued that these non-UPC entities could serve as “anchor defendants” giving the Central Division jurisdiction. Bosch disagreed and sought referral to a German Local Division instead. Initially, the Central Division (Paris) sided with Bosch: in two orders issued in December 2025 and January 2026, it declared that it lacked jurisdiction and referred the claim to the Local Division Düsseldorf arguing that Article 33(1) UPCA only applied if all defendants are domiciled outside the UPC territory (docket no. UPC_CFI_809/2025).

Court of Appeal's ruling. On 3 July 2026, the Court of Appeal (docket nos. UPC-CoA-4/2026 and UPC-CoA-13/2026), under presiding judge and UPC president Dr. Grabinski overturned that decision and referred the claim back to the Central Division. Setting out four guiding principles and taking a pragmatic approach, the court held that the Central Division had jurisdiction even where only one or some of the defendants are domiciled outside the UPC territory to avoid "parallel proceedings before different divisions and the risk of conflicting decisions".

Why this matters. Claimants have more options when filing an action which (also) includes defendants from non-UPC countries. This may also lead to a rise in case numbers at the Central Division given the high workload of the German Local Divisions and the decision against a proactive distribution of cases the UPC Administrative Committee took on 3 July 2026.