InterDigital v Amazon: The UPC Pushback Against ASI-Equivalent Interim Licensing In A Post-Brexit Landscape

In a post-Brexit context falling outside the scope of EU Regulation No 1215/2012 (Brussels I bis), the Local Division of Mannheim the UPC, in its Order of 22 December 2025 (UPC_CFI_936/2025), confirmed in full its ex parte order of 30 September 2025, rejecting Amazon's application for review.

The dispute arises in a global SEP/FRAND conflict between InterDigital (owner of a large SEP and non-SEP portfolio) and Amazon (implementer), involving parallel proceedings before the UPC (Mannheim), the Munich Regional Court, the UK Patents Court, as well as actions in Brazil and the US.

Before the UK High Court (Patents Court), Amazon started proceedings on 29 August 2025, relying on contractual FRAND/RAND rights under ITU-T declarations governed by Swiss law and seeking wide-ranging "Final Relief". In parallel, interim or adjustable licensing mechanisms were raised in the pleadings as part of the FRAND framework, prior to any final determination. Following the ex parte ant