Two multijurisdictional standard essential patent (SEP) disputes have settled in the wake of significant developments in key venues. On April 3, Ericsson and Lenovo announced that they had agreed to a global end to litigation between them, and to have their remaining disputes on fair, reasonable, and nondiscriminatory (FRAND) licensing issues—pertaining to the companies’ respective cellular SEPs—be resolved through arbitration. The deal was announced soon after Ericsson filed a UK Supreme Court appeal challenging a UK Court of Appeal judgment that deemed the company an unwilling licensor for not offering an interim license to Lenovo. Days earlier, a separate dispute between Nokia and Amazon over video streaming technology also reached a global settlement following a series of developments related to injunctions in Germany and the US.

Ericsson v. Lenovo

As detailed in RPX’s prior coverage, the dispute between Ericsson and Lenovo first hit the courts in October 2023, when Ericsson filed a trio of US lawsuits in the Eastern District of North Carolina, including one seeking a FRAND determination; and a pair of investigations before the US International Trade Commission (ITC), where it sought an exclusion order (essentially, injunctive relief barring the import of infringing products, and the only form of relief offered by the ITC). Additional litigation filed by Ericsson in Latin America led to the imposition of injunctions against Lenovo, including cases in Brazil and Colombia. However, it was Lenovo that brought the campaign’s UK litigation against Ericsson—asking the court to set the terms of a FRAND license—and that also filed a case before Europe’s Unified Patent Court (UPC).

In late February 2025, the UK Court of Appeal overturned the UK High Court’s denial of Lenovo’s request for an interim license from Ericsson, ruling that a SEP implementer is entitled to an interim license prior to the court’s determination of a final FRAND license. This was the second case in which the UK Court of Appeal had held that an interim license was warranted, the first involving narrower circumstances: In Panasonic v. Xiaomi, the court held that a willing licensor in the position of patent owner Panasonic—which had filed the underlying UK litigation (thereby invoking its jurisdiction) and had undertaken to accept a court-determined FRAND license—would have offered an interim license to defendant Xiaomi. Here, in contrast, Ericsson was not the plaintiff in the UK action, and had not make a similar undertaking to accept such a license.

The impact of those distinctions was a key dispute on appeal. While the Court of Appeal found that Ericsson’s conduct in this dispute had been less “egregious” than Panasonic’s, it nonetheless reached the same conclusion: that a willing licensor would have offered an interim license under the circumstances, and that Ericsson had breached its obligation to negotiate in good faith by pursuing injunctive relief in other jurisdictions. It did so based on the same reasoning as in Panasonic: that a rational SEP owner would have wanted a license payment as soon as possible, and that by pursuing injunctive relief elsewhere, Ericsson was seeking “to achieve a better outcome” than the UK court would provide. The appellate court held that this strategy constituted holdup.

The Court of Appeal subsequently set a one-week deadline for Ericsson to offer an interim license, holding that if it did not do so by March 10, the court would automatically conclude that it had breached its FRAND obligations to the relevant standard-setting organization (SSO), the European Telecommunications Standards Institute (ETSI), and that it had acted as an unwilling licensor. Ericsson then declined to offer an interim license, as a result of which the court made those determinations regarding its conduct—after which Lenovo reportedly initiated a dispute with ETSI, invoking a clause of its intellectual property rights (IPR) policy concerning license availability.

On March 28, Ericsson asked the UK Supreme Court for permission to appeal the UK Court of Appeal’s decision, citing the ruling’s “far-reaching ramifications for the worldwide FRAND regime”. Ericsson asserted, in part, that by conditioning a finding of bad faith on the potentially different outcomes of its foreign actions, the UK decision “amounts to an act of ‘jurisdictional imperialism’” that “offend[s] against the principle of comity” (which concerns the recognition of judgments by foreign courts)—especially since, per Ericsson, the UK Court of Appeal had not found that the company had “done anything wrong in the other fora”. Additionally, Ericsson contended that the UK court had erred by favoring court-determined license terms over those negotiated by the parties, and that it had applied the wrong test for FRAND compliance—countering that Ericsson would meet its FRAND obligations, and could not be found to have acted in bad faith, if its offer were found to be in the FRAND range.

However, the parties’ April 3 announcement of a resolution brings that litigation to an end, along with all other proceedings worldwide—Ericsson’s press release specifically highlighting its litigation before the ITC.

Nokia v. Amazon

The first litigation in the Nokia v. Amazon dispute came in October 2023, when Nokia announced that it had sued Amazon in the US (before the ITC), Germany (including two lawsuits at the Düsseldorf Regional Court, one at the Munich Regional Court, and one at the Mannheim Regional Court), India, and the UK, as well as before the UPC (before its Munich Local Division)—also suing HP in those countries as well. The cases alleged infringement through Amazon’s Prime Video streaming service and various streaming devices, with HP targeted over devices alone, and came after licensing discussions allegedly spanning “a number of years” (per Nokia). (The litigation against HP settled in October 2024.) In July 2024, Amazon filed a countersuit in the District of Delaware, alleging that Nokia had infringed certain patents not declared standard essential through the provision of various products related to cloud services.

That same September came the first of two German infringement decisions for Nokia, when the Munich Regional Court held that Amazon streaming devices including the Fire TV Stick infringed the EP 2 375 749 patent through certain video decoding functionality. The court issued an injunction barring all sales in Germany.

The next notable development came at the ITC, when in late December, Administrative Law Judge (ALJ) Cameron Elliot issued a final initial determination (FID) that both found a violation as to four of the five asserted patents, rejected Amazon’s FRAND defense, and recommended an exclusion order. The following month, a second ALJ, Doris Johnson Hines, determined in another ITC action that Amazon had infringed an additional patent and also recommended an exclusion order.

Those recommendations were more broadly significant due to ongoing uncertainty over whether, in the current political climate, the ITC will issue exclusion orders in SEP disputes. In 2013, the Obama administration vetoed an exclusion order against Apple over a Samsung patent declared essential to 3G, citing the administration’s policy disfavoring injunctions in SEP litigation. In 2019, the first Trump administration withdrew that policy and replaced it with one arguing that injunctions should be available in both SEP and non-SEP actions, though the Biden administration withdrew that newer policy in 2021 with no replacement in favor of a case-by-case enforcement approach. Since the 2013 veto, the ITC has not issued any more final exclusion orders in SEP investigations, either because the Commission has held the asserted patents to be invalid or not infringed, or because the proceedings settled.

However, in late 2024 it appeared that this could change, both as a result of the recommendations for exclusion orders from ALJs Elliot and Hines as well as a series of filings by the Office of Unfair Import Investigations (OUII), commonly referred to as the ITC Staff Attorney, which participates in ITC investigations as a party representing the public’s interest. In September, the Staff Attorney issued a brief in one of the ITC actions brought by Ericsson against Lenovo in which it also backed the issuance of an exclusion order, having found that Ericsson appeared to have complied with its FRAND obligation, and because no showing had been made that an injunction would adversely affect the public interest. The Staff Attorney then doubled down on this view in a March 2025 response to questions issued by the full Commission in a review of ALJ Elliot’s decision against Amazon, again arguing against a categorical ban of exclusion orders in SEP disputes and reaching the same conclusions as to the parties’ respective FRAND compliance.

Meanwhile, another key development came in the UK, where on January 28 the Court of Appeal granted Amazon’s request to amend its pleadings to add a claim for an interim license—requesting an order requiring such a license, rather than just a declaration it was entitled to one—in the wake of the Panasonic v. Xiaomi decision, overturning a High Court ruling that denied its request. In early February, Amazon cited a then-upcoming hearing on the interim license issue in an ITC filing requesting an extension, prior to the full Commission’s decision to review ALJ Elliot’s decision (for which the aforementioned questions asked by the full Commission included one on the impact of the UK proceedings on the ITC litigation).  

Then, in February 2025, the Düsseldorf Regional Court issued another infringement ruling and injunction against Amazon—here found to infringe one of the two asserted patents (EP 2 271 048) through the Prime Video streaming service, over its support for media casting features, along with devices offering that functionality. This time, the court held that Nokia had to provide a €646.75M security (or around $708.8M USD as of the time of this publication) to enforce the judgment pending appeal.

On April 3, however, the parties announced that they had agreed to dismiss all of the litigation between them, including Amazon’s cloud countersuit. As characterized in an Ericsson press release, the parties agreed that the “remaining patent licensing dispute will be fully resolved through an arbitration process between the parties”.

Notably, with the settlement of both the Ericsson v. Lenovo and Nokia v. Amazon disputes, it still remains to be seen whether the ITC will issue a final exclusion order in a future SEP investigation—and whether such a decision will ultimately be vetoed by the president (whether Donald Trump or a successor).

For more on other notable SEP developments so far this year, stay tuned for RPX’s upcoming report on the first quarter.