Battlekart Europe SA v Chaos Karts 1 Limited & Ors
Decision date: 25 July 2025
Neutral citation: [2025] EWHC 1936 (IPEC)
Overall AI summary confidence: high
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: high
This case concerned European Patent 3 304 522 B8, asserted by Battlekart against Chaos Karts and others; the defendants admitted infringement of claim 11 if valid. The court held the skilled addressee for inventive-step purposes is a multidisciplinary team, accepted defendants' evidence that industry tracking/coordination systems (notably BlackTrax) formed part of the common general knowledge, and found claim 11 lacked inventive step over several prior disclosures. The court also construed claim 1(g) and found the patent contained added matter.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: high
The judge applied a multidisciplinary-team conception of the skilled addressee where the invention spans different technical fields, preferred expert evidence showing that established tracking/coordination systems formed part of the common general knowledge, and on that basis concluded it would have been obvious to such a team to apply those systems to conventional karting — rendering claim 11 invalid for lack of inventive step. The judge also construed the claim language about multiple electromagnetic sources to permit two sources that together include at least one infrared emitter, and found that the patent as filed nevertheless contained added matter.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The judgment observed (obiter) that relying on a single expert per side in a technically multidisciplinary case can leave evidential gaps that might warrant earlier case-management intervention, and that commercial uptake or sales evidence can be helpful but is not always necessary where an expert establishes industry familiarity.