DLP Limited v Coram UK Holding Limited

Court: High Court (Intellectual Property Enterprise Court)

Decision date: 25 September 2026

Neutral citation: [2026] EWHC 2448 (IPEC)

Overall AI summary confidence: high

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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

DLP sued Coram for infringement of GB 2,446,666 (an electric shower-waste pump and control unit). The court construed key claim terms, found the Premium and Bluetooth Pumps did not infringe (the wall-mounted backplate was not the removable housing cover or a housing with internal chambers as claimed) and rejected Coram's invalidity challenges for obviousness. The judge would have allowed DLP's proposed modest claim amendments if necessary.

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 claim language must be given its ordinary purposive meaning in context: a "unit" can require a single, complete, self-contained product and a "removable housing cover for closing the housing" requires direct physical interaction with the housing (the cover must touch/close the housing). Obviousness must be assessed without hindsight; absent a clear, obvious route a skilled addressee would have taken, merely imagining modifications to prior devices (e.g. boxing-in components or adding a watertight sub-chamber) does not render the claimed unit obvious.

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 suggested (obiter) that parts of an installed arrangement that rely on fixed building fabric (such as a house wall) will not ordinarily form part of a self-contained patented "unit". It also observed that lack of prior commercial adoption in a small, low-innovation market is not dispositive on obviousness, and that experts may properly confine evidence to the priority date.