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1 Düsseldorf Local Division UPC_CFI_87/2025 UPC_CFI_488/2025 Decision of the Court of First Instance of the Unified Patent Court delivered on 23 July 2026 concerning EP 2 449 782 HEADNOTES: If an NDA between the parties prevents one party from maki ng submissions or producing documents, and the other party, without reasonable justification, refuses to amend the NDA to enable such production, this shall be to the detriment of the latter party. In such cases, if a party refers to steps within the FRAN D negotiation programme and the Court is unable to examine these steps due to the other party ’s refusal to amend the NDA, the steps will be considered to have been taken in accordance with the Huawei v ZTE judg- ment. KEYWORDS: FRAND; NDA; unwilling licensee 2 CLAIMANT: InterDigital VC Holding ...