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1 Decision of the Court of First Instance of the Unified Patent Court Central Division (Section Munich) issued on 2 September 2026 HEADNOTES: 1. The requirement in Art. 138(1)(e) of the European Patent Convention that a European patent may be revoked if the proprietor is not entitled under Art . 60(1) should be interpreted as meaning that the proprietor does not have any rights to the patent. The burden of presentation and proof for facts establishing that the proprietor is not entitled lies with the claimant. It is therefore not sufficient for this ground of revocation to be successful that a claimant demonstrates that it has rights to parts of the subject-matter disclosed in a patent, e.g. as a co-inventor or the co-inventor’s successor in title. 2. Dependent claims are part of the paten ...