Interdigital Patent Holdings Inc & Anr vs Shenzhen Transsion Holdings Co Ltd & Ors on 1 July, 2026

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    Delhi High Court

    Interdigital Patent Holdings Inc & Anr vs Shenzhen Transsion Holdings Co Ltd & Ors on 1 July, 2026

    Author: Tushar Rao Gedela

    Bench: Tushar Rao Gedela

                      *      IN THE HIGH COURT OF DELHI AT NEW DELHI
                      %                                         Order reserved on: 01.04.2026
                                                                Order delivered on: 01.07.2026
                      +      CS(COMM) 1045/2025, I.A. 24409/2025, I.A. 30455/2025, I.A.
                             31617/2025, I.A. 2901/2026
    
                             INTERDIGITAL PATENT HOLDINGS INC & ANR                 .....Plaintiffs
    
                                                      versus
    
                             SHENZHEN TRANSSION HOLDINGS CO LTD & ORS
                                                                    .....Defendants
    
                      +      CS(COMM) 1046/2025, I.A. 24419/2025, I.A. 30456/2025, I.A.
                             31616/2025, I.A. 4343/2026 & I.A. 5389/2026
    
                             INTERDIGITAL PATENT HOLDINGS INC & ANR                 .....Plaintiffs
    
                                                      versus
    
                           SHENZHEN TRANSSION HOLDINGS CO LTD & ORS
                                                                  .....Defendants
                      Advocates who appeared in this case:
                      For the Plaintiffs :     Mr. Pravin Anand, Ms. Vaishali R. Mitttal, Ms.
                                               Gitanjali Sharma, Mr. Siddhant Chamola, Ms.
                                               Pallavi Bhatnagar, & Ms. Prachi Sharma,
                                               Advocates.
    
                      For the Defendants :     Mr. Saikrishna Rajagopal, Ms. Julien George, Mr.
                                               Vivek Ayyagari, Mr. Arjun Gadhoke, Mr. Ayush
                                               Saxena, Mr. Christo Sabu, Mr. Devanjan
                                               Chakravarty, Mr. Sanskar Dua, Mr. Soumya Singh,
                                               Ms. Priyam Lizmary Cherian and Mr. Vedam Anand
                                               Kumar, Advocates.
    
    
    Signature Not Verified
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    By:YASHRAJ           CS(COMM) 1045/2025 & 1046/2025                           Page 1 of 100
    Signing Date:03.07.2026
    12:05:35
                       CORAM:
                      HON'BLE MR. JUSTICE TUSHAR RAO GEDELA
    
                                                       ORDER
    

    TUSHAR RAO GEDELA, J.

    I.A. 24410/2025 in CS(COMM) 1045/2025 & I.A. 24420/2025 in
    CS(COMM) 1046/2025 (Seeking pro-tem security payment)

    SPONSORED

    1. These are applications filed by the plaintiffs under Section 151 of the
    Code of Civil Procedure, 1908 (“CPC“), seeking pro tem security payment.
    BRIEF FACTS:

    2. The plaintiff no.1 was established in the year 1972. Plaintiff no.2 is the
    current parent company and was established under the laws of Pennsylvania,
    USA, and is listed on NASDAQ. It claims to be one of the world’s largest
    research and innovation companies, uniting wireless communication and
    video communication technologies. It further claims to be a leading designer
    and developer of technology solutions and intellectual property for the mobile
    industry. Plaintiffs assert that they have developed and designed a wide range
    of advanced technologies used in digital and wireless products, including 2G,
    3G, 4G, 5G and IEEE 802, related products and networks. Plaintiffs claim a
    total revenue of about USD 549.9 million in the year 2023.

    3. Plaintiffs claim that their technological innovations are currently
    protected by more than 31,500 patents and applications worldwide, including
    more than 1,000 patents and patent applications in India. Over the last 15
    years, they claim to have invested more than USD 1 billion in research and
    development activities.

    4. Plaintiffs further claim that, owing to its long standing technological
    contributions to the telecommunication field, (including 5G patents), they
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    have disclosed to ETSI, as potentially standard-essential to wireless
    telecommunications standards, more than 150 3G UMTS patent families
    comprising more than 3,100 patents and applications, more than 470 4G LTE
    patent families comprising more than 6,700 patents and applications, and
    more than 450 5G NR patent families, comprising more than 4,600 patents
    and applications across multiple jurisdictions and telecommunication
    technologies. These patents and applications allegedly cover several key
    technologies relating to 3G, 4G and 5G telecommunications standards. They
    further claim that they actively contribute to the technical development of
    standards pertaining to digital cellular and wireless communications, among
    other technologies. As innovators and contributing participants in the wireless
    technology industry, the plaintiffs claim to respect and honour their
    commitments under the applicable intellectual property policies of the
    standards-development organizations of which they are members.

    5. Plaintiffs also claim that, in order to make this high-end technology
    available to other parties, they have committed to ETSI that they were
    prepared to grant licenses to their standard essential patents to implementers
    of ETSI wireless communications standards on fair, reasonable and non-
    discriminatory (FRAND) terms and conditions. Plaintiffs assert that their
    licensing practices are considered exemplary by the industry and they have
    been honoured with Licensing Achievement Awards by the Licensing
    Executives Society, alongside other winners such as IBM Corporation and
    Stanford University. Some of plaintiff’s past and present wireless licensees
    include Google, Apple, Asus, Ericsson, Huawei, LG, HTC, Fujitsu, Oppo,
    Vivo, Panasonic, Samsung, Seiko, Sony, Kyocera, Wistron, Pegatron, Arima
    Communications, Blu Smartphones, Inventec, Fairphone, ZTE, and Xiaomi.

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    Licensees through licensing platforms include Audi, BMW, Rolls-Royce,
    Skoda and Volkswagen, among others.

    6. The defendant no.1/Shenzhen Transsion Holdings Co. Ltd., was
    established in Shenzhen, China and is engaged in the business of
    manufacturing/selling/exporting smart phones under the brands ITEL,
    INFINIX and TECNO. It is stated that the said phones operate in accordance
    with 2G, 3G, 4G & 5G mobile standards. It is also stated that defendant no.1
    has a presence in more than 70 countries, including India, through defendant
    nos.2 to 5.

    7. In the 1980s, commercialisation of wireless communication technology
    was initiated and the first generation (1G) cellular system, which used
    analogue radio signals for voice communication emerged. Due to the lack of
    uniform international standards, there was a vast variation in technology and
    protocols from country to country. On account of such technological
    deficiency, the cellular phones could not operate globally, or even regionally,
    because of network incompatibility. In order to resolve this issue, various
    organisations commenced investigating the problem. It is stated that, from the
    year 2000 onwards, Long Term Evolution (LTE) systems and the standards
    were developed for the wireless transmission of high-speed data. The next
    generation of wireless technology is 5G, which offers faster speeds, lower
    latency, enhanced capabilities and greater reliability. It also allows greater
    connectivity across devices.

    8. Plaintiffs claim to be among the contributors to the development of
    technology that has become essential to the implementation of these
    standards.

    9. The dispute between the plaintiffs and defendants is regarding use of
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    plaintiff’s Standard Essential Patents (SEPs) with respect to 3G, 4G, 5G and
    HEVC (video coding) used by the defendants in their mobile phones.
    Plaintiffs claim that the defendants have remained unlicensed since launching
    their smartphones in the Indian market, atleast since April, 2016. Plaintiffs
    allege that the defendants’ mobile phones make unauthorised and unlicensed
    use of the plaintiff’s SEPs, amounting to infringement of those SEPs,
    including the suit patents. Plaintiffs claim that the defendant no.1 had a
    market share of 8.6% as of the closing year 2023. In the present case, the
    plaintiffs rely on some of its SEPs from their the entire portfolio which protect
    technology pertaining to 3G, 4G and 5G standards.

    10. Plaintiffs state that the defendants’ unwillingness to conclude a license
    from the plaintiffs would mean that the import, manufacture, sale, offer for
    sale and use of the defendant’s products amount to infringement of plaintiffs’
    SEPs. They further state that plaintiffs and similar owners of SEPs, have
    undertaken an obligation to grant licenses for the use of their SEPs to willing,
    end-user device manufacturers on fair, reasonable and non discriminatory
    (hereinafter referred to as “FRAND”) terms and conditions.

    11. Plaintiffs claim to have made numerous attempts to negotiate and
    execute a license agreement for their SEPs with the defendants since their first
    correspondence in June, 2019. However, the defendants are stated to have not
    shown true willingness to enter into a license agreement on FRAND terms.

    12. It is for this reason, the accompanying suit has been filed. While the suit
    is pending adjudication, the present applications have been filed seeking the
    following reliefs:

    “a. A direction to the Defendants for the payment of a pro-tem
    security deposit of monies directly to the Plaintiffs, for the
    unlicensed manufacture, import and sale of 3G, 4G and 5G
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    compliant devices, on the basis of FRAND offer(s) made by the
    Plaintiffs to the Defendants, or any other amount as deemed fit by
    this Hon’ble Court in order to secure the rights and interests of the
    Plaintiffs during the pendency of the Plaintiffs’ interim injunction
    application;”

    ARGUMENTS OF THE PLAINTIFFS:-

    13. Appearing for the plaintiffs, Mr. Anand, learned counsel submitted as
    under:

    13.1. Mr. Anand, learned counsel gave a brief overview of what a
    Standard Essential Patent (hereinafter referred to as “SEP”) is, and
    explained the need for the SEPs in the context of wireless
    communications globally. He submitted that the SEPs allow
    interoperability and compatibility between products made by different
    manufacturers to work together seamlessly across various jurisdictions.

    Learned counsel submitted that the standards are broadly categorized
    based on their source primarily de facto, collaborative and
    governmental and those based on access to intellectual property rights
    or openness in the development process, primarily open and close
    standards.

    13.2. Learned counsel elaborated on what are Standard Development
    Organisations (SDOs), submitting that these are voluntary and non-
    profit organisations that coordinate the development of standards.
    Some of the well-known SDOs are DVD Forum; 3GPP; CCSA
    (China); EPSI (Europe); ATIS (USA); TTA (Korea); TTC (Japan);
    TSDSI (India); IEEE- Institute of Electrical and Electronics Engineers;
    ISO- International Standards organization; ITU-T-International
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    Telecommunications Union and IEC-International Electrotechnical
    Commission.

    13.3. Coming to the present case, learned counsel submitted that the
    present applications are in respect of a claim for pro tem security
    sought by the plaintiffs. He would contend that the basis for pro tem
    security emanates from the implementor’s obligation to necessarily
    secure the SEP holder and provide a rendition of accounts when
    making unlicensed use of its SEPs. He would submit that, unlike a
    relief of interim injunction on the ground of infringement, a claim for
    pro tem security does not require the Court to assess deeper issues like
    validity and essentiality on merits.

    13.4. Learned counsel submitted that the plaintiffs had filed four
    previous suits, in that, two suits against Xiaomi and two against Oppo
    bearing CS (COMM) 295/2020 & CS (COMM) 296/2020 titled
    Interdigital Technology Corporation & Ors. vs. Xiaomi Corporation
    & Ors.
    ” decided on 15.11.2021; and CS (COMM) 692/2021 &
    CS(COMM) 707/2021 titled “Interdigital Technology Corporation &
    Ors. vs. Guangdong Oppo Mobile Telecommunications Corp. Ltd. &
    Ors.
    ” decided on 05.11.2024. He submitted that all four suits were
    decreed in respect of patents which are identical to the patents in the
    present suits. He refers to the final judgment and decree passed in those
    suits which are placed at pages 172 and 175 of the Convenience
    Compilation handed over the Bench. He also refers to the interim
    orders passed in the same suits in respect of the pro tem security sought
    by the plaintiffs.
    Learned counsel also handed over to the Bench the
    order passed by the learned Division Bench in FAO(OS)(COMM)
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    47/2024 titled “Guangdong Oppo Mobile Telecommunications Corp.
    Ltd. & Ors. vs. Interdigital Technology Corporation & Ors” decided
    on 31.05.2024.

    13.5. Touching lightly upon what according to him is the manner in
    which infringement of an SEP may be proved, he explained that it is
    done by (i) mapping plaintiff’s patent to the standard to show that the
    patent is an SEP and (ii) showing that the defendants’ device also maps
    to the standard. This, according to him, is akin to the Law of
    Transitivity. In order to demonstrate that the patent maps onto the
    standard, courts ordinarily consider claim charts which can be mapped
    to the standard and for the purposes of demonstrating that the
    defendants’ device conforms to the said standards, the Courts could
    also consider test reports which show that the device conforms to the
    standard.

    13.6. Learned counsel for the plaintiffs submit that the present suits
    have been filed essentially based on five patents which are enumerated
    as under:

    CS(COMM) 1045/2025
    13.6.1. Indian Patent No. 295912 (IN’912 patent) titled
    “DYNAMIC RESOURCE ALLOCATION, SCHEDULING AND
    SIGNALING FOR VARIABLE DATA RATE SERVICE IN LTE” granted
    on 19.04.2018.

                                13.6.2.     Indian   Patent    No.   313036   (IN'036   patent)   titled
                                "METHOD           AND         SYSTEM     FOR        A      WIRELESS
    

    TRANSMISSION/RECEIPT” granted on 22.05.2019.

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    13.6.3. Indian Patent No. 320182 (IN’182 patent) titled
    “IMPLICIT DRX CYCLE LENGTH ADJUSTMENT CONTROL IN
    LTE_ACTIVE MODE” granted on 10.09.2019.

    13.6.4. Indian Patent No. 319673 (IN’673 patent) titled
    “METHOD AND APPARATUS FOR ENHANCING DISCONTINUOUS
    RECEPTION IN WIRELESS COMMUNICATION SYSTEMS” granted
    on 02.09.2019.

    13.6.5. Indian Patent No. 262910 (IN’910 patent) titled “A
    METHOD FOR TRANSFERRING DATA OVER AN ENHANCED
    DEDICATED CHANNEL (E-DCH), A WIRELESS
    TRANSMIT/RECEIVE UNIT AND A BASE STATION THEREOF”

    granted on 24.09.2014.

    CS(COMM) 1046/2025
    13.6.6. Indian Patent No. 308108 (IN’108 patent) titled
    “METHODS AND APPARATUS FOR IN-LOOP DE-ARTIFACT
    FILTERING” granted on 26.02.2019.

    13.7. Learned counsel for the plaintiffs drew attention to the field of
    invention described in the complete specifications, as well as the
    eighteen claims contained therein. Learned counsel has also
    painstakingly taken this Court through the claim charts which
    demonstrate claim mapping of the Indian patents with the 3GPP
    standards for the purpose of essentiality analysis. Learned counsel
    submitted that in the last six years, commencing from the year 2019,
    the plaintiffs have provided more than 100 claim charts to the
    defendants for the purposes of executing FRAND agreement. In order
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    to substantiate the essentiality, as an example, learned counsel referred
    to IN’036, which corresponds to EP Patent no.2485558 and submitted
    that the said patent was subject matter of a lawsuit in the UK Court
    between the plaintiffs and Lenovo bearing Case No.HP-2019-000032,
    wherein, by the order dated 29.07.2021, the said patent has been held
    to be valid and essential to the Release 8 of LTE and that it had been
    infringed. Thus, according to him, the essentiality of the patent IN’036
    has already been tested and its validity upheld by the UK Court. An
    appeal was preferred by the plaintiffs, however, was dismissed by the
    Appellate Court vide the judgment dated 19.01.2023.
    13.8. In order to demonstrate that the plaintiffs were willing licensors
    and ready to execute an agreement, the plaintiffs had sent a number of
    claim charts to the defendants. It was submitted that the aforesaid IN
    036 was sent to the defendants along with the claim chart which was
    discussed. Learned counsel also referred to a number of
    correspondences emanating after the claim was submitted to the
    defendants, particularly the letter dated 25.08.2025. Learned counsel
    would contend that the letter dated 25.08.2025 is relevant for the
    reason that though the plaintiffs’ offer dated 25.05.2025 complied with
    the commitment to grant FRAND license in respect of plaintiff’s SEP
    portfolio, the defendants continued to question the accuracy of
    CounterPoint’s reports.

    . He also submitted that the
    defendants were also made aware of the determination of royalty for a
    patent license between the plaintiffs and Samsung, in which the
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    International Chamber of Commerce Arbitrators recognized
    approximately USD 131 million of recurring revenue per year for eight
    years. However, learned counsel submitted that the defendants
    remained unwilling licensee inasmuch as neither did they agree to the
    FRAND offer of the plaintiffs nor did they agree to invoke arbitration
    to decide the disputes.

    13.9. Learned counsel also contended that there are a number of
    judgments of this Court whereby it has been held that pro tem security
    payment is an ad-interim relief meant to balance equities between the
    parties and is the implementor’s obligation in the negotiation phase
    itself. He also contended that the threshold for establishing a prima
    facie case for pro tem security payment is lower as no detailed
    exploration of facts is needed. According to learned counsel, the relief
    sought by way of a pro tem security payment is not assessed in the
    same manner as an interim injunction since only equities are to be
    balanced where the SEP holder stands at a disadvantage vis-a-vis an
    implementor.

    13.10. Learned counsel would emphasize that the payment of pro tem
    security also becomes necessary inasmuch as during the pendency of
    the suit, the implementor, i.e. the defendants in this case continue to
    sell their devices which use the SEPs in question. Thus, the lack of
    security works to the disadvantage of not only the SEP holder like the
    plaintiffs, but also other willing licensees who choose to pay license
    fees for the same patents. Learned counsel also submitted that there are
    a large number of cases where pro tem security has been directed to be
    deposited. In fact, according to learned counsel, if the plaintiffs are
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    able to prima facie demonstrate validity and essentiality of even one of
    the suit patents, the plaintiffs are entitled to pro tem security payment
    as against the entire SEP portfolio. He would submit that as
    demonstrated above, IN 036, as an example, has not only been held to
    be essential and valid by the UK Court between IDC and Lenovo,
    case No: HP-2019-000032, Neutral Citation Number: [2021] EWHC
    2152 (Pat), but even the defendants therein could not question its
    essentiality and validity. Similarly, learned counsel would submit that
    the plaintiffs had provided the defendants with more than 100 claims in
    the last six years, yet, the defendants for one reason or the other has
    been delaying the issue of execution of FRAND License. It is in that
    context, learned counsel would submit that the plaintiffs have been
    able to demonstrate that the defendants are an unwilling licensee.
    13.11. In order to substantiate that the plaintiffs are willing licensors and
    that they have complied with the FRAND obligations, learned counsel
    would submit that the defendants were approached way back in the
    year 2019 and subsequently in the year 2020, which negotiations are
    continuing till date. Learned counsel would submit that the
    correspondence exchanged between the parties would clearly
    demonstrate that the plaintiffs had complied with their FRAND
    obligations. In fact, the parties are stated to have exchanged several
    offers and counter-offers. The tabulated form of offers and counter-
    offers is extracted hereunder:

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    1. Plaintiff’s first offer

    2. Defendant’s first
    counteroffer

    3. Plaintiff’s second Offer

    4. Defendant’s second
    counteroffer

    5. Defendant’s third
    counteroffer

    13.12. In order to further demonstrate that defendants are unwilling
    licensees, learned counsel also emphasized that in order to resolve the
    FRAND licensing rates, the plaintiffs offered resolution through a
    neutral and independent third-party Arbitration Tribunal. However, the
    defendants are stated to have refused such alternate dispute resolution.
    That apart, the plaintiffs have gone to the extent of sharing the list of
    patents forming their SEP Portfolio with the defendants under the letter
    dated 01.03.2024. Moreover, learned counsel reiterates that the
    plaintiffs have shared 100 claim charts for 3G, 4G and 5G SEPs
    demonstrating essentiality and infringement of such patents by the
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    defendants’ devices vide the e-mails dated 19.03.2024, 30.03.2024,
    25.05.2024 and 31.05.2024.Additionally, learned counsel would also
    submit that the parties have had atleast twelve extensive meetings
    including 4 full-day meetings in China for technical discussions on the
    SEP portfolio. The plaintiffs are stated to have also provided detailed
    explanations on the rationale and computation of the royalties proposed
    in its offers made to defendant no.1 on 03.07.2025 and 25.08.2025. As
    asserted above, learned counsel would submit that the e-mails dated
    03.07.2025 and 25.08.2025 clearly indicated the royalties that were
    being paid by other licensees. However, the non-response by the
    defendants to enter into a FRAND license agreement on account of
    aforesaid facts, according to the learned counsel, demonstrates that the
    defendants are an unwilling licensee.

    13.13. In order to buttress that the plaintiff’s SEP portfolio is tried and
    tested, learned counsel would submit that the plaintiffs have disclosed
    to ETSI several patents covering 3G, 4G and 5G which include (i)
    more than 150 3G UMTS patent families comprising more than 3100
    patents and applications; (ii) more than 470 4G LTE patent families
    comprising more than 6700 individual patents and applications and (iii)
    more than 450 5G NR patent families, comprising more than 4600
    patents and applications. Learned counsel emphatically stated that for
    the very same portfolio of the plaintiffs, companies like Apple, Google,
    Oppo, Samsung, Huawei, Lenovo, LG, ZTE, HTC, Kyocera, Sony and
    Xiaomi have already accepted licenses which include the suit patents
    too.

    13.14. Learned counsel would contend that despite requests, particularly
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    the request made on 08.05.2025, the defendant no.1 has failed to
    disclose the requisite sales data which is usually the action undertaken
    by every willing licensee in order to complete the negotiations with
    respect to execution of a FRAND License Agreement. He also
    contended that the unwillingness of the defendants to obtain license on
    FRAND terms is also clear from the fact that no security has been
    offered by the defendant no.1 despite six years of continuous
    negotiations which is further confirmed by the unreasonably low
    counter-offers made by the defendant no.1.

    13.15. In order to demonstrate that not only are the defendants unwilling
    licensees but also habitual offenders, learned counsel referred to other
    litigations filed by SEP holders against defendant no.1 consequent
    whereupon, the defendant no.1 settled the matter by executing license
    agreements. He also informs that there are other litigations pending not
    only in India but in foreign jurisdictions as well.
    13.16. In order to strengthen the case of the plaintiffs for payment of pro
    tem security, learned counsel would contend that the defendants are in
    a precarious financial condition in the following manner:

    a. Transsion India faces significant contingent risks,
    including a customs duty dispute with the DRI involving
    paid under protest.

                                      b.    A transfer pricing adjustment of
                                      c.    Transsion India has investigations involving a
    

    vendor’s director amounting to freezing of a bank account
    balance of

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    d. A major customer, Defendant no. 5, G Mobiles India
    Pvt Ltd. has bad financial health and Transsion India’s
    dependence might affect its financial health.

    e. Transsion India has no immovable assets in India.”

    13.17. Dilating further, learned counsel would also submit that the
    defendant no.5- G Mobiles India Private Limited has a negative net
    worth and has never been positive for five reporting years. Learned
    counsel would contend that the precarious financial condition of
    defendants is a good and valid ground for grant of pro tem security as
    held by this Court in Nokia vs. Oppo (DB) (supra) and Dolby vs. Lava
    (supra).

    13.18. To the question of the quantum of pro tem security which needs
    to be deposited, Mr. Anand, learned counsel would emphatically
    contend that it should be based on the offer of the plaintiffs and not the
    counter-offer of the defendants. He would rely on the judgment of
    Phillips vs. Oplus, Dolby vs. Lava and Voiceage vs. HMD (German
    Decision) for the said proposition. Predicated thereon, learned counsel
    would submit that the defendants ought to be directed to deposit a pro
    tem security amount based on the plaintiff’s last offer of 07.05.2025
    for on all 3G, 4G and 5G compliant devices sold in
    India by the defendants.

    13.19. In order to demonstrate how various decisions of this Court have
    quantified the pro tem security amount to be deposited by defendants,
    learned counsel had handed over to the Court a detailed chart which is
    reproduced hereunder:

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    Sl. Title Technology Form of Whether Whether Quantum of security and
    No. type security ex- PLAs shown basis
    licensee to Defendant
    relationsh before pro-

                                                                       ip?           tem
                                                                                  security?
                1.       OPPO v. 3G, 4G, 5G, Bank                  No           No           Quantum -
                         InterDigita HEVC    Guarantee                                       (****** Figures)
                         l     (DB)                                                          Confidential
                         2024
                                                                                                Basis - 18.75% of global
                                                                                                Counteroffer
                                                                                                (India share)
                2.       Nokia       v. 3G, 4G, 5G    Deposit   in Yes          No              Quantum - Confidential
                         Oppo                         court                                     (****** Figures)
                         (DB)        -                                                          Confidential
                         2023
                                                                                                Basis -
    
                                                                                                23% Last-paid royalty
                                                                                                (India share)
                3.       Xiaomi v. 2G, 3G             Deposit   in No           No              Quantum - INR 100 X
                         Ericsson                     court                                     devices sold
                         (DB) 2014
                                                                                               Basis - Ad-hoc and
                                                                                               random figure picked by
                                                                                               the Court
                4.       Dolby v. Advanced            Deposit   in No           No             Quantum 1 - First pro-
                         Lava 2025 Audio              court                                    tem based on Defendants'
                                   Coding                                       (Seen only by counteroffer of INR 5.13
                                   (AAC)                                        the    Court. per device
                                                                                Not       the
                                                                                Defendants'    Quantum 2 - Second pro-
                                                                                counsel     or tem based on Plaintiffs' per
                                                                                representativ device rates, Quantum is
                                                                                es)            confidential
    
                                                                                                Basis - Dolby's rates.
    
                                                                                                The Court saw the PLAs
                                                                                                but only for "satisfying the
                                                                                                Court's conscience" that
                                                                                                the similar rates were
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                                                                                   charged to 3rd parties.
    
                                                                                  Court held that PLAs are
                                                                                  not necessary for deciding
                                                                                  pro-tem.
    
                                                                                  PLAs were not disclosed
                                                                                  to Defendants.
                5.       Atlas v. Wi-Fi 6      Deposit     in No   No             Quantum 1 - (******
                         TP Link               court                              Figures)
                         2023                                                     Confidential
    
                                                                                  Basis   -      1/5th     of
                                                                                  Defendants' counteroffer
    
                                                                                  Quantum 2 - INR 1 crore
                                                                                  (subsequently revised)
    
                                                                                  Basis - Ad-hoc figure
                6.       Philips v. 3G, 4G     Deposit     in No   No             Quantum - INR 53 crores
                         Oplus                 court
                         2023                                      (Seen only by Basis - Plaintiff's rates X
                                                                   counsel and Defendants' sales
                                                                   the    Court.
                                                                   Not by party
                                                                   representativ
                                                                   es)
                7.       Philips v. 3G, 4G     Real estate   No    No            Quantum - Real Estate
                         Oppo                                                    was attached as security.
                         2022
                                                                                  Basis - This was an offer
                                                                                  made by Defendants, and
                                                                                  accepted by Plaintiffs.
                8.       Philips v. 3G, 4G     Bank          No    No             Quantum - INR 1000
                         Xiaomi                Guarantee                          crores
                         2020
                                                                                  Basis - This was an ad-
                                                                                  hoc amount in the order.
    
                                                                                  Defendant agreed to secure
                                                                                  the Plaintiff for this
                                                                                  amount on Day 1.
    
                                                                                  The order was to keep the
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                                                                                   money in a bank account,
                                                                                  and later modified to a
                                                                                  bank guarantee.
                9.       Philips v. 3G, 4G     Real estate   No   No              Quantum - Real Estate
                         Vivo 2020                                                was attached as security.
    
                                                                                  This was an offer made by
                                                                                  Defendants, and accepted
                                                                                  by Plaintiffs.
                                                                  (Seen       by
                                                                  counsel and
                                                                  the     Court
                                                                  after grant of
                                                                  security)
                10.      Dolby v. Advanced     Deposit    in No   No             Quantum - INR 34 per
                         Das,     Audio        court                             device, later reduced to
                         Dolby vs Coding                                         INR 20 per device.
                         GDN      (AAC)
                         (Oppo,                                                   Later, parties entered an
                         Vivo)                                                    interim arrangement for
                                                                                  INR 30 per device.
    
                                                                                  Total amounted to at least
                                                                                  INR 91 crores.
    
                                                                                  Basis - Lower than
                                                                                  Plaintiffs' offer (INR 38
                                                                                  per device) but higher than
                                                                                  Defendants' counteroffer.
                11.      Philips v. DVD        Deposit    in No   No              Quantum - INR 45 per
                         Bhagirathi            court                              device
                         and
                         Philips                                                  Basis - Ad hoc
                12.      Ericsson   2G, 3G     Payment to No      No              Quantum 1-
                         v.                    Plaintiff
                         Mercury                                  (Seen only by       (a) GSM: 1.25% of
                                                                  the Court)          NSP
    
                                                                                      (b) GPRS + GSM:
                                                                                      1.75% of NSP
    
                                                                                      (c) EDGE + GPRS +
                                                                                      GSM: 2% of NSP
    
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                                                                         (d) WCDMA/HSPA:
                                                                        2% of NSP
    
                                                                        (e) Dongles:      USD
                                                                        2.50
    
                                                                    Quantum 2:
    
                                                                        (a) GSM: 0.8% of
                                                                        NSP
    
                                                                        (b) GPRS + GSM:
                                                                        0.8% of NSP
    
                                                                        (c) EDGE + GPRS +
                                                                        GSM: 1% to 1.1% of
                                                                        NSP
    
                                                                        (d) WCDMA/HSPA:
                                                                        1% to 1.1% of NSP
    
                                                                    Basis: Ericsson's rates
    
                                                                    The Court did not see
                                                                    PLAs for Quantum 1.
    
                                                                    The Court saw PLAs for
                                                                    Quantum
    
                                                                    However, Court clarified
                                                                    that the determination was
                                                                    not reflective of FRAND
                                                                    rates.
                13.      Ericsson    2G, 3G    Payment to No   No   Quantum 1:
                         v. Gionee             Plaintiff
                                                                        (a) GSM: 1.25% of
                                                                        NSP
    
                                                                        (b) GPRS + GSM:
                                                                        1.75% of NSP
    
                                                                        (c) EDGE + GPRS +
                                                                        GSM: 2% of NSP
    
    Signature Not Verified
                                                                        (d) WCDMA/HSPA:
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                                                                                              2% of NSP
    
                                                                                             (e) Dongles:       USD
                                                                                             2.50
    
                                                                                         Basis: Ericsson's rates.
    
                                                                                         Quantum 2:
    
                                                                                             (a) GSM: 0.8% of
                                                                                             NSP
    
                                                                                             (b) GPRS + GSM:
                                                                                             0.8% of NSP
    
                                                                                             (c) EDGE + GPRS +
                                                                                             GSM: 1% to 1.1% of
                                                                                             NSP
    
                                                                                             (d) WCDMA/HSPA:
                                                                                             1% to 1.1% of NSP
    
                                                                                         Basis      -        Interim
                                                                                         arrangement         arrived
                                                                                         between parties.
    
    
                      CONTENTIONS ON BEHALF OF THE DEFENDANTS:-
    

    14. Appearing for the defendants, Mr. Saikrishna Rajgopal, learned counsel
    handed over the Bench, submissions on behalf of the defendants on aspects
    regarding pro tem security and the applicable law. He would submit as under:

    14.1. Fundamentally, learned counsel would submit that the Standards
    Setting Organizations (SSOs) and its members have an incentive to
    push for the inclusion of the technology since such inclusion ensures a
    market for such technology. He also contended that the SSOs are under
    no obligation to check whether patents declared to be essential or valid
    are in fact and therefore primarily all SEP claims are self-declarations
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    made by the patentees themselves. Equally, he would submit that the
    SSO does not prescribe what the FRAND rates or term would be.
    Finally, it is the National Courts globally who determine all the
    aforesaid aspects of an SEP portfolio. He would contend that,
    therefore, there is no presumption attached to essentiality or validity of
    an SEP or a patent comprising such a portfolio. According to him, in
    the lack of such positive authentication and verification, the question of
    claim of pro tem deposit, that too on an assumption and the self-
    serving statement of the plaintiffs that its suit patents or the SEP
    portfolio are in fact essential and valid, does not arise.
    14.2. Elaborating further, he would submit that ETSI, the SSO in the
    present case has clearly stated that it has not checked the validity of the
    information nor the relevance of the identified patents/patent
    applications to the ETSI standards and thus, cannot confirm or deny
    that such patents are either essential or potentially essential. Thus,
    unless such parameters are first established by the plaintiffs in
    accordance with law, no such order of payment of pro tem security can
    be passed by this Court. In support of the aforesaid contention, learned
    counsel relied upon Unwired Planet International Ltd and Anr. Vs
    Huawei Technologies (UK) Co Ltd.; [2020] UKSC 37 and Intex
    Technologies (India) Ltd. vs. Telefonaktiebolaget LM Ericsson
    (PUBL
    ); 2023: DHC:2243-DB.

    14.3. According to learned counsel for the defendants, the plaintiffs are
    obliged to demonstrate that (i) the patent maps to the standard through
    claim charts and (ii) the impugned devices manufactured and sold by
    the defendants conform to the asserted standard. Learned counsel
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    would submit that in the present case, both are lacking. In the first
    instance, the defendants have, in their reply, challenged the claim of
    the plaintiffs that the claim charts of the patents, do map onto the
    Standard. This fulfils the requirement of Rule 2(f) of the High Court of
    Delhi Rules Governing Patent Suits, 2022. And in the second, learned
    counsel would submit that the plaintiffs have failed to provide any test
    reports of the defendants’ devices in the suit pertaining to
    smartphones/mobiles and the test report provided in the HEVC suit is
    flawed. He further contended that the claim chart filed by the plaintiffs
    assert certain specific standards, however, the defendants have
    nowhere in its technical specifications acceded to any compliance with
    the said standards. Therefore, it would be imperative for the plaintiffs
    to first test the defendants’ devices to ascertain as to whether the
    technologies can exist outside the asserted standards as well.
    According to learned counsel, only when both the aforesaid steps are
    demonstrated by the plaintiffs, will it be in a position to establish
    infringement of its claimed SEP. Consequently, as per the learned
    counsel, the issue of pro tem security deposit, till prima facie
    establishment of infringement of patents is reached, cannot be
    considered or appreciated.

    14.4. Referring to a number of judgments, learned counsel would
    submit that what can be carved from the ratio laid down therein is that
    even for grant of pro tem, a prima facie establishment of essentiality
    and validity has to be made out. He would contend that reliance indeed
    can be placed on certain surrounding factors, however, such factors
    need to be undisputed by both the parties. He submitted that the
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    determination of quantum or pro tem deposit should be based on
    objective material which may be relied upon by the Court. In the
    absence of any such surrounding factors or objective material coupled
    with the requirement of prima facie establishment of essentiality and
    validity, no orders for grant of pro tem security can be passed.
    14.5. Differing from the arguments addressed by Mr. Pravin Anand,
    learned counsel, in respect of the judgment in Nokia Technologies OY
    versus Gwangduang Oppo
    ; 2023:DHC:4465, learned counsel
    emphasized on the factual differences arising in both the cases.
    He
    would submit that in Nokia Technologies (supra), the defendants Oppo
    ((i) was an ex-licensee of Nokia for the patents asserted in the suit and
    was negotiating to renew its licensing arrangement; (ii) had made an
    offer to render interim payments to Nokia; (iii) had filed a FRAND rate
    setting suit in China, which was construed to be a prima facie
    admission that Nokia did own SEPs, which OPPO was required to
    license; (iv) In 11 out of 13 proceedings filed globally, Courts had
    found OPPO to be infringing Nokia’s SEPs; (v) There was objective
    material to determine the quantum of the pro tem security – the past
    license agreement and (vi) OPPO’s financial health was precarious in
    nature. In contradistinction, in the present case, the vital factual
    differences are that (i) no prior licensing arrangement between the
    parties; (ii) no such offer has been made by Transsion; (iii) No such
    proceedings has been filed by Transsion and (iv) No such adverse
    finding has come against Transsion. However, Plaintiff’s claimed SEPs
    has been held to be non-essential in the past and the corresponding
    foreign patent of two of the suit patents have been held to be invalid in
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    China; (v) There is no objective material on record. Plaintiffs have not
    even filed their third party license agreements and (vi) Defendant no.4
    has immovable assets in India, which are valued at
    Transsion is of robust financial health with net profits for the year
    2024-2025 being as follows: a) Defendant No. 2 (Ismartu) –

                                       in 2024-2025; b) Defendant No. 4 (G Mobile) -                   in
                                2024-2025 and c) Defendant no.5 (S Mobile) -                    in 2024-
    

    2025. Relying on the said judgment, learned counsel submitted that in
    the said case the Court had, before it, objective material to determine
    the quantum of pro tem deposit, in the form of previous licensing
    arrangement between the parties. Whereas, no such objective material
    is available in the present suits.

    14.6. The defendants rely upon the judgment of this Court in Oppo vs.
    IDG of the learned Division Bench reported in 2024:DHC:4547-DB,
    particularly para 96 and 99 wherein it was held that it would be
    necessary in a contested case for the Court to form a prima facie view
    before granting any interim relief and simultaneously had noted the
    facts in the judgment in Nokia Technologies (supra) and observed that
    in that case there was an objective material which may have propelled
    the Court to direct deposit of pro tem security.
    Learned counsel stated
    that the learned Division Bench in Oppo (supra) held that the decision
    in Nokia Technologies (supra) is not an authority for the proposition
    that pro tem deposits can be ordered without even considering the
    defences raised by the defendants and taking a prima facie view. The
    Court also held that pro tem deposits cannot be punitive in nature.
    14.7.
    Similarly, learned counsel also assailed the reliance of the
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    plaintiffs on the judgment of this Court in Dolby vs. Lava,
    2025:DHC:5426 to submit that the Court was impelled to grant pro
    tem for the reason that (i) the defendants Lava’s technical expert had
    admitted that Dolby’s patents are essential to the asserted standard and

    (ii) the plaintiff’s third-party licenses which were filed by Dolby were
    also considered. However, in the present case, learned counsel would
    contend that the defendants had neither admitted the plaintiff’s
    essentiality nor validity of the patents as SEPs, rather, the same has
    been challenged by the defendants. Moreover, in the present case,
    learned counsel contends that plaintiffs have refused to file any of its
    third party license agreements (hereinafter referred to as “TPLAs”)
    despite the defendants issuing notice of production dated 13.11.2025.
    In fact, according to learned counsel, an adverse inference against such
    non-production ought to be drawn by this Court against the plaintiffs.
    On similar grounds, the reliance of the plaintiffs in CS(COMM)
    575/2023 titled “Atlas Global Technologies LLC versus TP Link
    Technologies Co. Ltd. and Ors.
    ” decided on 28.08.2023 [vide order
    dated 13.10.2023, the Court reduced the 1/5th of the counteroffer] was
    also distinguished and differentiated on facts.

    14.8. The case of CS(COMM) 574/2019 titled “Koninklijke Phillips
    N.V. v/s Oplus Mobitech India Private Limited and Others
    ” decided
    on 20.12.2023, relied upon by the plaintiffs have been sought to be
    differentiated on facts. Learned counsel contended that the rates quoted
    by Phillips had already been judicially determined as FRAND in
    foreign jurisdictions and accordingly, were applied with slight
    adjustment in India. In that case, Oplus neither negotiated nor provided
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    a counter-offer. Learned counsel also submitted that Oplus neither
    made a categorical statement that it does not use the technology
    covered by the suit patents nor did it have any assets in India. Phillips
    had placed third-party licences along record and access to the same
    was provided to the counsel for the defendants and lastly the Court had
    relied on the FRAND finding of a foreign court.
    According to learned
    counsel, in contradistinction, it is claimed that defendant no.1 had been
    continuously negotiating in good faith and making counter-offers;
    taken a categorical stand that suit patents are not essential as they do
    not map to the asserted standards; defendant no.4 has immovable assets
    in India valued at ; despite notice of production plaintiffs
    have failed to file or produce third-party license agreements and that
    there has been no FRAND determination for the HEVC portfolio and
    the offers of the plaintiffs have been held to be contrary to FRAND
    terms by the UK High Court in Interdigital vs. Lenovo. Learned
    counsel copiously read a number of paragraphs of the judgement in
    Interdigital vs. Lenovo rendered by the UK High Court to emphasize
    that the plaintiffs are guilty of not having complied with FRAND
    offers as its rates were found to be more than double the FRAND rate.
    In fact, it is submitted that the decision found Interdigital guilty of
    Maximum Revenue Extraction. Taking support from the said
    observations, learned counsel would submit that the plaintiffs latest
    offer dated 07.05.2025 on which the pro tem security deposit is
    predicated, has been found to be four times higher (opinion of the
    economic expert of the defendants) when compared to the effective
    rate determined by the UK Court of Appeals in Interdigital vs. Lenovo
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    [(2024) EWCA Civ 743]. It is also contended that the plaintiffs failed
    to provide the computational basis of the offer made on 07.05.2025 nor
    have they given any valuation for the suit patents or their Indian
    portfolio.

    14.9. Contrary to the assertions made on behalf of the plaintiffs that the
    EP counterparts of 2 of the 4 asserted suit patents have been held to be
    essential by the UK Court of Appeals, learned counsel would
    vehemently contend that the plaintiffs are guilty of suppression of the
    fact that the Chinese counterparts of the very same patents have been
    invalided in another jurisdiction. The details are mentioned below:

    a. IN 262910 – Supreme People’s Court of People’s Republic of
    China held that the Chinese equivalent is invalid as it lacks
    inventive step by decision dated 17.12.2024.
    b. IN 313036 – one of the Chinese counterpart i.e.
    ZL200780004185.1 was invalidated by CNIPA in Notification of
    Decision of Invalidation 48997 dated 19.02.2021.

    14.10. In view of the above, learned counsel would contend that this
    Court, therefore, needs to apply its mind as to whether the views of the
    Supreme Court of China are to be endorsed or that of the UK Court of
    Appeals. Additionally, he would contend that the aforesaid
    invalidations by itself would demonstrate that the suit patents need to
    be technically reviewed and the claims of essentiality or validity ought
    not to be accepted at face value. In furtherance to the said submission,
    learned counsel also relies upon the judgment in Nokia Cooperation
    vs. Interdigital Technology Cooperation [(2007) EWHC 3077 (Pat)]
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    wherein the Court in para 134 concluded that 3 out of 4 patents in issue
    before it are not essential to the standard, leaving the issue for a
    decision on the evidence to be adduced at trial.
    14.11. The other contention of Mr. Saikrishna Rajgopal, learned counsel
    is as to whether any direction for deposit of pro tem can be passed
    without verifying what are the royalties being paid by other
    competitors of the defendants. In other words, he would contend that in
    the absence of any TPLA entered into by the plaintiffs with the
    similarly placed competitor and ascertaining the rates that might have
    been fixed there, the question of pro tem deposit would not arise at all.

    He would submit that every party would have its own peculiar terms
    and conditions in respect of commercial transactions surrounding the
    sale of their devices. Surely, according to him, commercial terms not
    agreed to by other parties, cannot be saddled upon the defendants. This
    would ensure a level playing field. Relying on Dolby vs. Lava-
    2025:DHC:5426, he would submit that when there are a significant
    number of competitors, some of whom may be in a better bargaining
    position, that by itself may be a relevant factor to be taken into
    consideration. He also relied upon certain judgments like Dolby
    International AB and Anr. vs. Das Telecom Private Limited and
    Ors.- CS(COMM
    ) 1426/2016 decided on 10.12.2019 and
    Telefonaktiebolaget LM Ericsson (PUBL) vs. Mercury Electronics
    and Anr.- CS(OS
    ) 442/2013 decided on 19.03.2013, to submit that
    SEP holders consistently seek higher rates than what is FRAND.
    Equally, he insisted that third-party license agreements are also
    fundamental to suits like the present one. He insisted that the plaintiffs
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    failed to place on record TPLAs and also failed to furnish a copy to the
    defendants despite the defendants issuing disclosure notice dated
    13.11.2025.

    14.12. Dilating further on the aforesaid issue, learned counsel referred
    to many foreign judgments to submit that what was initially offered by
    SEP claimants as FRAND rates were found to be not within the
    FRAND terms and the said courts interfered and reduced the rates
    drastically. Thus, according to him, the rates quoted by plaintiffs
    without testing the veracity and the assertion of the suit patents as to
    whether those are essential and valid, cannot be relied upon to quantify
    pro tem security.

    14.13. Citing three cases namely, InterDigital vs. OPPO (supra),
    Koninklijke Philips N.V. Vs VIVO Mobile Communication Co Ltd &
    Ors., CS(COMM
    ) 383/2020 decided on 17.11.2020 and Nokia
    Technologies vs. Hisense Group Holdings Co. Ltd & Anr
    ;
    CS(COMM) 645/2025 decided on 22.09.2025, learned counsel would
    submit that the relevance and importance of the TPLAs needs to be
    underscored. In that, he would contend that the aforesaid three cases
    were quickly resolved on the basis of disclosure of TPLAs to the
    defendants in those cases, one of which was a suit filed by the present
    plaintiffs itself. Thus, according to him, in the absence of TPLAs, the
    quantification of pro tem and a direction to deposit that cannot be
    passed.

    14.14. Referring to the cases of Nokia vs. Oppo (DB), Dolby vs. Lava
    (supra), Atlas vs. TP Link (supra) and Philips vs. OPlus- 2023,
    learned counsel would submit that in most of the cases the Court had
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    the benefit of TPLAs before passing any direction or quantifying pro
    tem. He would also contend that as per the High Court of Delhi Rules
    Governing Patent Suits, 2022, monetary payment would be permissible
    only in exceptional situations and only upon infringement being prima
    facie established. He also relied upon Rule 4A(viii) of the High Court
    of Delhi Rules Governing Patent Suits, 2022, which mandate the
    plaintiffs to file TPLAs on record to submit that the plaintiffs have
    deliberately not filed such TPLAs on record. Nor has the plaintiffs
    filed the TPLAs despite notice of production dated 13.11.2025 issued
    by the defendant no.1.

    14.15. Learned counsel referred to Clause 7 of the Non-Disclosure
    Agreement (hereinafter referred to as ‘NDA’) to submit that the parties
    were ad idem that the confidential information being shared inter se is
    provided ‘as is’ with no warranties expressed or implied. He would
    contend that it is on this basis that the plaintiffs shared its patent lists
    with the defendants on the categorical stand that the plaintiffs makes
    no representation as to its accuracy or to the essentiality of the patents.
    In other words, learned counsel would contend that the plaintiffs itself
    was unsure as to whether the patents comprising the list were essential
    or not. If that be so, learned counsel would contend that the premise on
    which the pro tem security is sought, itself, is without any stable
    foundation and cannot be granted.

    14.16. Learned counsel categorically asserted that the defendant no.1
    had engaged in technical evaluation of plaintiff’s claim, earnestly. He
    would submit that analysis of about 50 claim charts were furnished by
    defendant no.1 to the plaintiffs between 17.06.2024 and 30.10.2024.

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    He would submit that between January 2024 and July 2025, the parties
    had engaged in about a dozen meetings, however, the plaintiffs did not
    provide any basis to verify the FRAND claims for the offers made by
    them. That apart, plaintiffs did not also give any computational basis or
    objective material to verify the FRAND claims particularly the offers
    made on 10.10.2024 and 05.05.2025. He would submit that defendant
    no.1 repeatedly requested the plaintiffs to be reasonable in the offers
    made by them as defendant no.1 was operating in developing countries
    like Africa and South-East Asia. However, the plaintiffs failed to
    revise its offers substantially.

    14.17. So far as counter-offers made by defendant no.1 is concerned,
    learned counsel would submit that the said counter-offers were without
    prejudice and cannot be made the basis of an admission for the
    purposes of quantifying pro tem. He would contend that this Court vide
    judgment dated 13.10.2025, in Philips vs. M. Bathla and Anr.-
    2025:DHC:9079 observed that correspondences between the parties
    are without prejudice to the rights and contentions that might be raised
    by a defendants in suits pertaining to SEP portfolios. Thus, according
    to him, the counter-offers cannot be considered as admissions and
    resultantly, cannot form the edifice whereon pro tem security is either
    quantified or directed to be deposited. On the issue of delay, learned
    counsel vehemently contended that contrary to the false submission
    that delay in negotiations were on account of defendants’ willful and
    deliberate inaction on the negotiations, the plaintiffs itself kept silent
    for 18 consecutive months i.e. 23.04.2021 to 03.11.2022. Thus, it is the
    plaintiff which is blameworthy of the delay caused in both the parties
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    negotiating FRAND terms.

    14.18. Relying on Intex Technologies (India) Ltd vs
    Telefonaktiebolaget LM Ericsson (PUBL), Neutral Citation

    2023:DHC:2243-DB, (DB) learned counsel would submit that a
    licensor like the present plaintiffs, will be considered as a willing
    licensor only if it gives a FRAND offer and if it offers a supra-FRAND
    offer, such plaintiffs are likely to be considered an unwilling licensor.
    He further contended that the Court needs to assess whether prima
    facie the patent is infringed apart from assessing whether the implentor
    is an unwilling licensee and whether the royalty sought is on FRAND
    terms. According to him, unless the aforesaid conditions are prima
    facie fulfilled, no order on pro tem deposit can be passed.
    14.19. Contrary to a false and frivolous submission of the plaintiffs that
    defendant no.1 is under financial distress, learned counsel asserted that
    defendant no.1 has a robust financial health which is evidenced by the
    financial statements for FY 2024-25 and that the defendants companies
    are operationally sound and profitable entities. According to learned
    counsel, the latest balance sheets of defendant no. 2, 4 and 5
    demonstrate that these defendants are profitable and have a positive net
    worth of Rs.244 Crores, Rs.28 Crores and Rs.157 Crores respectively.
    He submitted that defendant no.2 has assets in India. In fact, he would
    submit that the plaintiff’s CA report itself admits that defendant no.1
    has good and sound financial health. Thus, there being no distress
    financial or otherwise of any of the defendants including defendant
    no.1, the question of inability of the defendants together or defendant
    no.1 to make good any direction by this Court of payment of any
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    monies or royalties at a later stage or after the judgment and decree, if
    any, is passed, is a mirage and untrue. Thus, the defendants being in
    pink financial health, there is no occasion for this Court to pass any
    orders directing deposit of pro tem security.

    14.20. Without prejudice to the rights and contentions of the defendants,
    learned counsel next argued on the quantification or computation of the
    pro tem deposit. He would submit that the plaintiff’s demand a pro tem
    deposit of of their offer of for a period of
    years. However, the plaintiff’s offer cannot form basis of the pro tem
    deposit as (i) plaintiffs have failed to provide any computational basis
    for such offer ever during negotiations nor has it provided such basis
    despite notice dated 13.11.2025 issued by defendant no.1; (ii) the
    prayer of pro tem being based on the claim that the offers made by the
    plaintiffs are FRAND, it was incumbent on the plaintiffs to produce
    TPLAs and provide access to the same to this Court as well as the
    defendants; and (iii) the plaintiff’s offer was for the entire portfolio
    which comprise patents with no corresponding protection in India and
    thus, cannot be the basis to direct pro tem security deposit against the
    defendants. Learned counsel would contend that unless the plaintiffs
    provides valuation of the suit patents or its Indian portfolio, no such
    direction for deposit of pro tem security can either be quantified or
    directed. He would submit that as per the term sheet provided by
    plaintiffs vide the e-mail dated 26.08.2025, apparently, out of
    only was payable annually till while the
    remaining was attributable to past sales. Therefore, he would contend
    that even going by the offer of the plaintiffs at the highest, it could
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    have sought security for defendant no.1’s India sales percentage of
    on an annual basis.

    14.21. Without prejudice to the aforesaid submission, he would submit
    that the defendants are willing to give a security in the form of, Option
    1- on the basis of defendants’ economic expert report, for cellular suit
    patents and for HEVC suit patents,
    from the date of the filing of the present suit and Option 2
    being, a bank guarantee for an amount equivalent to of the last
    counter-offer of made by the defendants.

    14.22. Learned counsel would submit that the aforesaid options are
    completely without prejudice to their rights and contentions including
    the challenge to the validity and essentiality of the suit patents and
    without the same being considered as an admission of any
    infringement of any of the suit patents.

    14.23. Mr. Saikrishna Rajgopal, learned counsel would also contend that
    this Court needs to also appreciate the provisions of Section 48 of the
    Patents Act which grants certain rights to the patentees. It was his
    endeavour to convince this Court that at best or at the highest, and
    without admitting, the plaintiffs could lay claim against the defendants
    in respect of only those patents which are registered in India under the
    said Act and the protection is extended to such patents under Section
    48
    of the Act. In other words, those patents which may form part of the
    SEP portfolio but not protected under Section 48 of the Act, cannot
    form part of the suit claim. Thus, viewed from that perspective,
    according to him, the direction to deposit pro tem security for the
    alleged entire SEP portfolio may not have any legal basis or foundation
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    to stand on. Thus, the applications being bereft of legal foundation,
    ought to be rejected and dismissed in limine.

    REJOINDER ON BEHALF OF THE PLAINTIFFS

    15. In rejoinder, Mr. Pravin Anand, learned counsel for the plaintiffs submit
    as under:

    15.1. To the argument of the defendants that even for passing orders
    directing deposit for payment of pro tem security, a prima facie case
    for establishing essentiality and validity of the SEP portfolio is
    necessary, learned counsel contends that the same is contrary to the
    law laid down by the Division Bench of this Court in Nokia vs. OPPO
    which was ultimately upheld by the Supreme Court too. He relies on
    para 59 of the said judgment in support of his contention.
    To the issue
    of essentiality and validity to be established prima facie, learned
    counsel relies upon Nokia vs. Oppo (DB) (supra) and Intex vs.
    Ericson (DB)(2023) (supra) particularly para 114 of Intex vs. Ericson
    which is as under:

    “114. Further, the learned Single Judge in Nokia vs Oppo (supra)
    has set an impossibly high bar for admission in a case of Standard
    Essential Patent FRAND infringement, i.e., there has to be an
    unequivocal admission on (i) essentiality and validity of the suit
    patents (ii) fact of utilization (iii) fact that such utilization, absent
    payment of liability would amount to infringement (iv) that the
    royalty rate proposed by the plaintiff was FRAND. If there was an
    unequivocal admission on all four counts, there would be no
    necessity to file a suit for infringement at all and otherwise also,
    same would mean seeking/passing of a final decree at the interim
    stage!”

    15.2. Learned counsel asserts that plaintiffs had extensively discussed
    atleast three suit patents during technical discussions with defendant
    no.1 and had proven a prima facie case of essentiality and validity.

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    Despite this, learned counsel would submit that defendant no.1 had
    never challenged the suit for patents any time prior to filing of the suit.
    The three suit patents being IN 036, IN 673 and IN 182. Relying on
    para 58 of Nokia vs. Oppo (DB) (supra), learned counsel would
    contend that a pro tem order being a temporary arrangement can be
    passed without a detailed explanation on merits.
    He would contend that
    even in Dolby vs. Lava (supra), this Court had made similar
    observations in para 38 to 40 of its judgment.

    15.3. So far as ‘surrounding factors’ are concerned, learned counsel
    would contend that even on that score there is enough material to
    demonstrate that the plaintiffs have (i) executed more than 50
    worldwide licenses for its telecommunication SEP portfolio; (ii)
    enforced the same patents against third-parties like Oppo and Xiaomi;

    (iii) obtained previous orders directing deposit of pro tem for the same
    patents against third parties like Oppo; (iv) executed licenses with
    parties like Apple, Xiaomi, Google etc. who are much larger than the
    defendants; (v) considered the counter-offers provided by defendants
    while consistently stating that they respect plaintiff’s IP and are willing
    to take license; and (vi) the precarious financial condition of the
    defendants. Thus, the parameters in respect of “surrounding factors”

    are complete and satisfied.

    15.4. Learned counsel also would contend and reiterate that TPLAs are
    not a prerequisite for the grant of pro tem deposit. Relying on Intex vs.
    Ericson (DB) (supra), learned counsel would contend that the
    defendants have no right to seek furnishing of the TPLAs before any
    direction for pro tem security deposit is made. Moreover, the TPLAs, if
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    at all, may be a relevant consideration at a time when the Court is
    required to draw FRAND terms and conditions. Thus, FRAND terms
    are not sine qua non for the computation or direction to deposit pro
    tem.

    15.5. Apart from the aforesaid, learned counsel stoutly contended that
    during the pendency of the present applications, the Brazilian Court
    vide order dated 30.01.2026 has upheld the validity and essentiality of
    counter parts of two of the suit patents i.e. IN 673 and IN 036. Learned
    counsel also submitted that the UK High Court had vide the order
    dated 29.07.2021, upheld the validity and essentiality of the EP (UK)
    2485558 which is the same as IN 036 in Case no. HP-2019-000032
    titled “Interdigital Technology Corporation vs. Lenovo Group Ltd”.

    He also submitted that the appeal filed thereagainst was dismissed by
    the Appellate Court on 19.01.2023. Thus, according to him, the
    essentiality and validity one of the suit patents i.e. IN 036 has been
    upheld by a court of competent jurisdiction. In another proceeding, the
    UK Court of Appeal overturned the decision of the UK High Court
    invalidating the EP (UK) counterpart of IN 910 which is the suit patent
    vide order dated 09.02.2023.

    15.6. Learned counsel reiterated that the plaintiffs have filed claim
    charts in respect of each of the suit patents to demonstrate that the
    relevant claims of the suit patents map onto the ETSI/3GPP standards.
    Additionally, it is stated that the plaintiffs have filed invention
    declarations in respect of each of the suit patents before the SSO-
    ETSI/3GPP.

    15.7. Learned counsel also reaffirmed that the plaintiffs have verified
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    that the defendants’ devices are conforming to the 3G, 4G and 5G
    standards as per the technical specifications displayed by the
    defendants themselves. Learned counsel would forcefully assert that
    though there was no obligation, yet the plaintiffs have also conducted
    technical analysis and testing of the defendants’ devices to establish
    that those devices conform to the 3G, 4G and 5G standards and
    implement the suit patents. Thus, even on that aspect, there is a reliable
    report confirming the mapping of the claim chart of the suit patents
    with the actual devices.

    15.8. Learned counsel next relied and reaffirmed the submissions that
    defendant no.1 is an unwilling licensee. He relied upon the extensive
    correspondences exchanged between the parties in the last many years
    of negotiations to contend that the unwillingness to obtain a license is
    apparent from the language used by the defendants in their
    correspondences. He would contend that the defendants were also
    informed and furnished copies of the US annual reports in which the
    plaintiffs are mandated under US Law to disclose the license fee
    publicly, so as to ensure that the defendant no.1 has an informed choice
    as to what were the rates entered into by the plaintiffs with other third-
    parties. He further contended that it was only upon such information
    having been provided to defendant no.1 under the e-mail dated
    25.08.2025 that defendant no.1 vide the e-mail dated 20.09.2025 gave
    its third counter-offer which was an increase to the extent of
    over the last offer. He submitted that in the said e-mail, defendant no.1
    yet again reiterated its willingness to obtain license of the plaintiff’s
    patents while at the same time disagreeing to refer the dispute to
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    Arbitration.

    15.9. To the argument of the defendants that the suit patent IN 420806
    is also a subject matter of another suit bearing CS No. 1146/2026
    pending consideration before the Coordinate Roster Bench whereby
    the same plaintiffs are seeking injunction without averring that the said
    IN 420806 is an SEP and thus, there is contradiction between the two
    suits, Mr. Anand, learned counsel, would demonstrate the distinction
    between the two suits by the following table:-

    S.No. Suit Number Asserted Patent(s) Technology Whether an
    SEP or not?

    
                              1        CS(COMM)         IN 295912             Cellular (3G, YES
                                       1045/2025        IN 313036             4G, 5G)
                                                        IN 320182
                                                        IN 319673
                                                        IN 262910
    
                              2        CS(COMM)         IN 308108             HEVC             YES
                                       1046/2025
    
                              3        CS(COMM)         IN 420806             AVI and VP9      NO
                                       1146/2025
    
    
    
                      SURREJOINDER ON BEHALF OF THE DEFENDANTS:
    

    16. In surrejoinder, Mr. Saikrishna Rajagopal, learned counsel would
    submit as under:

    16.1. Mr. Saikrishna Rajagopal, learned counsel would submit that in
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    previous occasions this Court has directed deposit of pro tem on
    perusing the TPLAs and in those cases where such agreements were
    not available has proceeded to quantify and direct deposit of pro tem
    on the basis of counter-offers made by the defendants. Thus, according
    to him, since no TPLAs have been filed on record by the plaintiffs, if at
    all the Court has to pass any orders on pro tem, though without
    prejudice to and independent of all other contentions, the Court has to
    examine the said issue by the counter-offer made in this case.
    16.2. Out of five suit patents, he would contend that four suit patents
    have been held to be invalid in China and therefore, if at all any
    computation has to be done, the basis can only be on one suit patent
    which has not been held to be invalid. Learned counsel had handed
    over the Bench a chart indicating the suit patent and the issue of
    validity or essentiality upheld or denied by other foreign courts. The
    same is taken on record.

    16.3. To the argument that defendant no.1 is facing ED proceedings,
    learned counsel had handed over the Bench an order dated 31.08.2024
    of the High Court of Allahabad in M/s Ismartu India Private Limited
    vs. State of UP and Anr.
    : Neutral citation 2024:AHC:141124
    whereby the HDFC Bank bearing account no.00880330002032 was
    directed to be de-freezed to submit that the said account is operational.
    Thus, the contention that the defendants are facing any such
    proceedings which puts a question mark on their financial viability is
    unfounded.

    ANALYSIS AND FINDINGS:

    17. This Court has heard lengthy and extensive arguments of Mr. Pravin
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    Anand, learned counsel for the plaintiffs and Mr. Saikrishna Rajgopal, learned
    counsel for the defendants on a number of days. With their valuable
    assistance, the voluminous documents on record as also the judgments
    referred and relied upon by the parties have been considered. At the outset this
    Court also appreciates the supporting teams of both learned counsel, who have
    rendered excellent assistance which is apparent from the crisp written notes,
    charts, convenience compilations and meticulous preparation of slides.

    18. The requirement of maintaining standards in wireless
    telecommunications needs to be underscored inasmuch as the said standards
    allow interoperability or compatibility between different devices
    manufactured by different manufacturers with different operating systems and
    softwares so as to ensure that consumers are able to operate and use their
    smartphones seamlessly in different countries across the world. That apart, it
    appears that the standards which are usually uniform globally, do also impact
    the pricing of the mobile devices both for the companies as well as the
    consumers. Ordinarily, it appears that the standards are set by the market
    forces as also by governments wherever the compliance of law is required.

    19. It further appears that such requirements of standardisation had given
    impetus to voluntary and non-profit organisations commonly called Standard
    Development Organisations or Standard Setting Organisations. Certain formal
    SDOs have specific structures, formal policies and try to balance the interest
    of developers and implementers. There are a number of such SDOs all over
    the world.

    20. Given the aforesaid background, this Court would now examine the
    present controversy. The plaintiffs in the present case have filed the
    applications under consideration seeking deposit of pro tem security by the
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    defendants. Both parties have placed before this Court a number of judgments
    which need to be considered and appreciated and may be applied to the facts
    of the present case, should the need arise.

    Jurisprudence on Pro Tem:

    21. In the opinion of this Court, it may be relevant to consider as to whether
    at the time of consideration of a direction to deposit pro tem security amount,
    the Court needs to necessarily consider the issue on merits or in other words,
    conduct an exploration of facts in order to reach a conclusion. The judgment
    in the case of Dolby vs. Lava (supra), clearly held that when a Court is
    examining an issue relating to pro tem security deposit, it need not explore the
    facts deeply in the manner as may be required when the Court needs to
    appreciate an application seeking interim injunction based on allegations of
    infringement of patents. In para 23, 24 and 32 of the said judgment, it was
    held as under:

    “23. From a plain reading of the aforesaid extracts, it is abundantly
    clear that the Court has the power, in order to balance the equities
    between the parties, to pass a pro tem order as a temporary
    arrangement without a detailed examination of the merits of the
    case. The Division Bench highlighted the difference between the
    level of scrutiny required for the purposes of passing a pro tem order
    and an order of interim injunction.

    24. The underlying principle, as emphasised by the Division Bench,
    is that while the implementor has a right to enjoy the benefits of the
    invention of the SEP holder, it has to pay reasonable compensation
    or furnish an appropriate security in the interregnum.

    **** **** ****

    32. Placing reliance on the judgements of the Division Bench in
    Intex v. Ericsson (supra) and Nokia v. Oppo (supra), the Coordinate
    Bench held that in order to balance equities between the parties,
    Court has the power to pass orders and put in place a temporary
    arrangement, without a detailed explanation on merits.”

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    22. It is to be borne in mind that at the stage of consideration of pro tem
    security deposit, it is the balance of equities between the parties which is the
    paramount consideration and thus, only a prima facie understanding of
    whether the patents are essential and valid are to be considered. What such
    parameters and considerations would be, is entirely dependent upon the facts
    arising in each case and cannot be applied across the board as a straightjacket
    formula. This is for the reason that the SEP holders on one hand, and the
    implementers on the other are largely trans border commercial entities, co-
    existing in a commercial ecosystem having diverse commercial interests,
    globally. What may be a relevant economic consideration for a particular
    country in Asia may not be relevant at all in a country in Europe or for that
    matter in Africa. It may also vary depending on the country’s economic
    policies, telecommunication regime, availability of a robust eco system in
    respect of interoperability of various softwares and applications required, all
    of which may have a direct or an indirect impact on the prices of the mobile
    devices. Thus, the considerations of or directions for deposit of pro tem
    security cannot be made subject matter of a straightjacket formula.

    23. It must also be kept in mind that the SEP holders base their claim on
    SEP portfolio in respect of 3G, 4G or 5G technologies in the absence whereof
    it may not be possible to achieve the optimum functionality of a particular
    device of a manufacturer. Thus, when SEP holders place on record the claim
    charts of their patents comprising the SEP portfolio and attempt to map the
    same with the technical specifications of the manufacturers supported by
    either an expert’s affidavit or a technical evaluation report, the depth of
    consideration and evaluation for the purposes of passing orders for deposit of
    pro tem security may not be at the same threshold at which a Court may be
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    evaluating in order to pass interim injunction orders on the allegations of
    infringement of suit patents. Therefore, the said evaluation for pro tem deposit
    would be at a lower threshold.

    24. As to what are the obligations and responsibilities cast upon the SEP
    holders on one hand and the implementors on the other, as envisaged by the
    SEP regime, the learned Division Bench of this Court in Intex vs Ericsson
    (DB
    ) (supra) has succinctly laid down as under:

    “68. Accordingly, the Standard Essential Patent regime envisages a candid
    and transparent negotiation between a willing licensor (Patentee) and
    willing licensee (implementer).

    69.A licensor will be considered a willing licensor only if it gives a
    FRAND offer and in certain situations provides information necessary,
    subject to confidentiality agreement, for a licensee to offers a supra-
    FRAND offer i.e. exorbitant royalty rates, it will not be considered a
    willing licensor.

    70.Similarly, an implementer has no right of silence or inaction at this
    stage. It is not correct to suggest that without access to other agreements
    executed by the Patentee no counter-offers can be made.
    Normally, an implementer can take recourse to its own license agreements
    executed with other Standard Essential Patent proprietors/licensors, to
    determine an appropriate FRAND rate that it would be willing to pay or to
    determine if the rate offered by an Standard Essential Patent proprietor is
    FRAND or not. This is evident from the judgment of the Dutch Court of
    Appeal in Koninklijke Philips N.V. v. Wiko SAS [Case Number
    200.219.487/01 decided on 02.07.2019] wherein it has been held as
    under:-

    “4.37. Wiko pointed out that it does not have the licence agreements that
    Philips concluded with other parties for the same patent portfolio, so
    that Wiko is unable to demonstrate that Philips’ proposal is not FRAND.
    Even apart from the fact that according to the above findings, Wiko
    failed on several points to substantiate its arguments and furnish
    evidence of its arguments and its defence should already fail on this
    basis, this point of view does not hold, Wiko concluded licence
    agreements for UMTS and LTE portfolios with Qualcomm, Huawei and
    Nokia. By providing insight into the fees and stipulations agreed upon
    with those parties in relation to (the value of) the SEPs held by those
    parties, Wiko could have substantiated (a suspicion of) the alleged fact
    that Philips’ offer was not FRAND and the alleged fact that its own
    counter-offer was FRAND; however, Wiko failed to do this. Under those
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    circumstances, the Court of Appeal does not see any reason to reverse
    the burden of proof or to assume an increased duty to contend facts and
    circumstances for Philips, as Wiko argued.”

    *** *** ***

    72.Further, the implementer has to either accept the licensor’s offer or
    give a counter offer along with an appropriate security in accordance
    therewith to prove its bonafides as in the interregnum it cannot freely sell
    its devices using such Standard Essential Patents. If no ad-hoc royalty is
    paid during the interregnum, such party benefits, to the disadvantage of
    other willing licensees, and gets an unfair competitive edge in the market.

    73.Accordingly, FRAND obligations have been interpreted to impose a
    burden not just on Standard Essential Patent holders, but on
    implementers as well. The Standard Essential Patents regime incorporates
    mutual reciprocal obligations on both the Essential Patent holder and the
    implementer. It is not a ‘one way street’ where obligations are cast on the
    Essential Patent holder alone. Consequently, the Standard Essential
    Patents regime balances the equities between the Patentee and the
    implementer and ensures a level playing field. This Court is also of the
    view that the conduct of the parties during negotiations is one of the key
    factors to be kept in mind while assessing whether a potential licensor and
    licensee were a willing licensor or a willing licensee. The said finding is
    normally fact sensitive.

    *** *** ***

    114. Further, the learned Single Judge in Nokia Vs. Oppo (supra) has set an
    impossibly high bar for admission in a case of Standard Essential Patent
    FRAND infringement, i.e., there has to be an unequivocal admission on (i)
    essentiality and validity of the suit patents (ii) fact of utilization (iii) fact that
    such utilization, absent payment of liability would amount to infringement

    (iv) that the royalty rate proposed by the Plaintiff was FRAND. If there was
    an unequivocal admission on all four counts, there would be no necessity to
    file a suit for infringement at all and otherwise also, same would mean
    seeking/passing of a final decree at the interim stage!

    115. In the opinion of this Court, the four-fold test casts an onerous burden
    upon the Standard Essential Patentee and that too at the interim stage itself.

    In fact, the said burden is completely alien to the patent jurisdiction and
    does not apply even in normal patent suits.

    116. It is also pertinent to mention that the learned Single Judge in Nokia
    Vs. Oppo
    (supra) judgment does not consider or discuss the Delhi High
    Court Rules Governing Patent Suits 2022, even when the said rules
    specifically empower this Court to pass deposit orders even on the first date
    of hearing.

    117. Moreover, if the four-fold test stipulated in paragraph 77 of the Nokia
    Vs. Oppo
    (supra) is applied, then effectively there will be no interim order
    like a temporary injunction or conditional order of deposit in the Standard
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    Essential Patent suits. Such a view, in the Court’s opinion, would be
    contrary to Section 48 of Patents Act, Code of Civil Procedure as well as
    Standard Essential Patent regime which is aimed at achieving a uniform
    standard in technologies. If the four-fold test is accepted, there will be no
    incentive to innovate and it will have a ‘Domino Effect’ as pointed out
    hereinabove.

    Consequently, the four-fold test in Nokia vs. Oppo (supra) is neither
    applicable at Order 39 Rule 10 CPC stage nor at Order 39 Rules 1 and 2
    CPC stage.”

    [emphasis supplied]

    25. It is apparent from a reading and understanding of the aforequoted
    paragraphs of the Intex judgment that there are certain obligations cast upon
    the implementer as also SEP holders under the SEP regime. Essentially, the
    learned Division Bench unequivocally held that the SEP regime primarily
    balances the equities between the SEP holders and the implementers, purely to
    ensure a level playing field. In fact, it was also held that the conduct of the
    parties during negotiations would be one of the key factors to assess whether
    the potential licensor and a licensee were a willing licensor or a willing
    licensee. The learned Division Bench was also of the opinion that the four
    fold tests propounded by the learned Single Judge in Nokia vs. Oppo, cast an
    onerous burden upon the SEP holders and that too at the interim stage itself
    which was not proper. It was also held that the said burden is completely alien
    to the patent jurisdiction and does not even apply in normal patent suits. In
    other words, the implementer too has obligations which cannot be wished
    away or be evaded by reference to non availability of TPLAs.

    26. It may be significant to note that this Court in Dolby vs Lava (supra)
    held that the Court is empowered to pass pro tem orders as a temporary
    arrangement without a detailed examination of the merits of the case.

    27. It may be of some relevance to take into account the ratio laid down by

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    the learned Division Bench of this Court in Nokia vs. Oppo (supra) where it
    was held that ordinarily a pro tem deposit should be directed after a prima
    facie finding of essentiality as well as validity of the suit patents. However, in
    case it appears to the Court after considering various facts surrounding the
    case that such challenge is merely an after thought, in such situations the facts
    pleaded by the plaintiffs may sufficiently justify directions for deposit of pro
    tem security without a full prima facie, adjudication on essentiality and
    validity. The relevant paragraphs are extracted hereunder:

    “81. Normally speaking, a pro-tem deposit should be directed only after a
    prima facie finding of essentiality and validity of the suit patents has been
    recorded, but in the present case where Oppo itself licensed the Standard
    Essential Patents of Nokia against royalty payments running into XXXXXXX
    under the 2018 Agreement over a three year period and admitted its
    obligation in law to secure a new licence agreement commencing July, 2021
    for Standard Essential Patents of Nokia, there arises a prima facie
    presumption that the challenge to essentiality and validity of Nokia’s patents
    is merely an afterthought. This Court is in agreement with learned counsel
    for Nokia that at this prima facie stage it would be fair to infer that no one
    pays good money for generally disputed patents. In fact, it was Oppo‘s case
    in its pleading before the learned Single Judge that during the course of
    pre-suit negotiations, the new licensing rate offered by Nokia was
    unreasonably higher than what was previously agreed to.”

    Validity and Essentiality of the Suit Patents:-

    28. Having regard to the aforesaid this Court now proceeds to examine the
    issue of validity and essentiality of suit patents.

    VALIDITY
    INDIAN PATENT NO. 295912 (“IN’912”)

    29. The invention claimed under IN’912 relates to wireless communication
    systems and more particularly, the present invention is related to a method and
    apparatus for dynamic resource allocation, scheduling as well as signalling
    for variable data rate service in long term evolution (LTE) systems. Under the
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    first preferred embodiment, high-level information including radio access
    bearer (RAB) and logical channel/ data flow ID and HARQ process ID are
    only transmitted at the configuration stage of an RTS data flow. The sequence
    numbers for the RTS data flow are assigned at the radio link control (RLC)
    Iayer in order to avail the reordering of packets at a receiver are handled at
    higher layers.

    30. The UE as claimed in Claim 1 of the patent is as follows:

    “We Claim:

    1. A wireless transmit/receive unit (WTRU) comprising:

    receiver for receiving a first allocation of resources for uplink
    communications; transmitter for transmitting uplink communications in
    response to the first allocation of resources; receiver for receiving control
    information indicating a second allocation of resources for uplink
    communications different from the first allocation of resources; and
    transmitter for transmitting uplink communications in response to the
    second allocation of resources for a single time duration and transmitting
    uplink communications at the first allocation of resources after the single
    time duration.”

    INDIAN PATENT No. 313036 (“IN’036”)

    31. IN’036 is titled as “METHOD AND SYSTEM FOR A WIRELESS
    TRANSMISSION/RECEIVER” and pertains to a wireless communication
    system. More particularly, the present invention pertains to a method and
    apparatus for providing as well as utilising a non-contention-based channel in
    a wireless communication system.

    32. It is a wireless communication system which comprises at least one
    evolved Node-B (eNB), a plurality of wireless transmit/receive units
    (WTRUs), and a non-contention-based (NCB) channel is established,
    maintained, and utilised. The non-contention based (NCB) channel is
    allocated for use by one or more WTRUs in the system for the purpose of
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    utilisation in different functions, and the allocation is communicated to the
    WTRUs. The wireless communication system analyses the allocation of the
    NCB channel as required, and the NCB channel is reallocated as required.

    33. The IN ‘036 patent is valid, in force, and has been renewed regularly.
    The plaintiffs have filed the copies of the registration certificate, complete
    specification, and the E-Register maintained by the Patent Office in the
    present proceedings.

    34. The Claims 1 of IN ‘036 of the patent, is as follows:

    “A wireless transmit/receive unit (WTRU) comprising a processor (125)
    configured to: receive, through a receiver (126), a first allocation from an
    evolved Node B (eNB), wherein the first allocation is an allocation of a non-
    contention based (NCB) uplink control channel, the first allocation
    comprises a configuration for transmitting scheduling requests over the
    NCB uplink control channel, and the configuration indicates a periodicity at
    which physical resources of the NCB uplink control channel are dedicated
    to the WTRU for transmitting scheduling requests;

    transmit, through a transmitter (127), a scheduling request over the NCB
    uplink control channel in accordance with the first allocation, wherein the
    transmitted scheduling request comprises a transmission burst, and
    presence of the transmission burst on NCB uplink channel resources
    assigned to the WTRU by the first allocation is indicative of a request for
    uplink transmission resources by the WTRU;
    monitor a downlink control channel;

    detect that a transmission on the downlink control channel is intended for
    the WTRU based on a WTRU identifier indicated in the transmission on the
    downlink control channel, wherein the transmission on the downlink control
    channel comprises a second allocation, the second allocation being an
    allocation of an uplink shared channel; and transmit, through said
    transmitter (127), data over the uplink shared channel in accordance with
    the second allocation.”

    INDIAN PATENT No. 320182 (“IN’182”)

    35. The invention is titled as “Implicit DRX Cycle Length Adjustment
    Control In LTE_Active Mode” and pertains to the field of wireless
    communication. As per Specification of IN’182, a method and apparatus are
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    disclosed in order to control discontinuous reception in a WTRU. The method
    may include defining a plurality of DRX levels in which each DRX level
    includes a respective DRX cycle length, as well as transitioning between DRX
    levels based on a set of criteria. Transitioning may be triggered by implicit
    rules, and the triggering may be invoked by a measurement event/a timer/a
    counter or a downlink command, for example. The transition between DRX
    states may also occur without explicit signalling.

    36. The Claim 1 of IN’182 is as follows:

    “We Claim:

    l. A method for controlling discontinuous reception, DRX, in a wireless
    transmit/receive unit, WTRU (402), the method comprising:

    the WTRU receiving a DRX configuration in a radio resource
    control, RRC message (406), the DRX configuration comprising a first
    DRX cycle length, a second DRX cycle length, and a value for a WTRU
    timer (418) to trigger a transition of DRX cycle length;

    the WTRU operating using the second DRX cycle length (a08);
    the WTRU receiving a trigger 412);

    the WTRU operating using the first DRX cycle length based on
    receiving the trigger (412);

    the WTRU starting the WTRU timer (418) upon beginning DRX
    operation using the first DRX cycle length;

    the WTRU determining that the WTRU timer (418) has expired;
    and responsive to determining that the WTRU timer has expired, the
    WTRU transitioning (422) from the first DRX cycle length to the second
    DRX cycle length the second DRX cycle length being a multiple of a first
    DRX cycle length.”

    INDIAN PATENT No. IN 319673 (“IN’673”)

    37. IN’673 is titled as “Method And Apparatus For Enhancing
    Discontinuous Reception Wireless Systems”. The claimed invention under
    IN’673 relates to wireless communication systems and, more particularly, a
    method and apparatus is disclosed for enhancing discontinuous reception
    (DRX) in wireless systems.

    38. The claimed method preferably includes a WTRU receiving DRX
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    setting information over a radio resource control (RRC) signal, and the
    WTRU receiving DRX activation information over a medium access control
    (MAC) signal. The claimed method may also include the WTRU grouping
    DRX setting information into a DRX profile and determining a DRX profile
    index associated with it.

    39. The Claim 1 of IN’673 is reproduced as follows:

    “We Claim:

    1.A method of discontinuous reception, DRX, for use in a wireless
    transmit receive unit, WTRU,(602), the method comprising:

    the WTRU (602) receiving DRX configuration information in a
    radio resource control (RRC) message, the DRX configuration information
    comprising a DRX cycle periodicity and a minimum active period;

    while in a RRC_CONNECTED state, the WTRU (602) receiving a
    data indication signal during the minimum active period of a DRX cycle;

    responsive to receiving the data indication signal, the WTRU (602)
    remaining in active time;

    the WTRU receiving a DRX activation signal in a medium access
    control, MAC, message; and
    the WTRU (602) resuming DRX using the received DRX
    configuration information in response to receiving the DRX activation signal
    in the MAC message.”

    INDIAN PATENT No. 262910 (“IN ‘910”)

    40. In IN ‘910 is titled as “A METHOD FOR TRANSFERRING DATA
    OVER AN ENHANCED DEDICATED CHANNEL (E-DCH), A
    WIRELESS TRANSMIT/RECEIVE UNIT AND A BASE STATION
    THEREOF”. The claimed invention under IN’910 pertains to wireless
    communications and, more particularly, relates to enhanced uplink (EU)
    transmission.

    41. As per the specification of IN ‘910, the claimed invention relates to
    quantising the amount of multiplexed data allowed by grants to match a
    selected E-TFC transport block size.

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    42. The scheduled and/or non-scheduled data allowed to be transmitted is
    increased/decreased relative to the grants so that the amount of data
    multiplexed into a MAC-e PDU closely matches the selected E-TFC transport
    block size.

    43. The claim 1 of the IN ‘910 is as follows:

    “WE CLAIM

    1. A wireless transmit/receive unit (WTRU) (1414) comprising:

    a receiver configured to receive at least one serving grant (1406)
    and at least one non-scheduled grant (1407), wherein the at least one
    serving grant (1406) is a grant for scheduled data transmission and the at
    least one non-scheduled grant (1407) is a grant for non-scheduled data
    transmission;

    characterized by
    a multiplexing device (MUX) (1410) configured to multiplex data
    of medium access control-dedicated channel (MAC-d) flows (1403) into a
    medium access control enhanced dedicated channel (MAC-e) protocol
    data unit (PDU) (1411); wherein the MAC-e PDU (1411) has a size not
    greater than the size of the largest enhanced dedicated channel transport
    format combination (E-TFC) that does not exceed a first size based at
    least on the at least one serving grant (1406) and the at least one non-
    scheduled grant (1407), wherein the multiplexed data includes scheduled
    data for transmission;

    an E-TFC selection device (1405) configured to select an E-TFC for
    transmission of the MAC-e PDU (1411), wherein the selected E-TFC does
    not exceed the first size; and
    a transmitter configured to transmit the MAC-e PDU (1411)
    processed in accordance with the selected E-TFC.”

    INDIAN PATENT NO. 308108 (“IN ‘108”)

    44. IN’108, is titled as “Methods And Apparatus for In-Loop De-Artifact
    Filtering” generally relates to video encoding and decoding and, more
    particularly, to methods and apparatus for in-loop de-artifact filtering. An
    apparatus includes an encoder (300) in order to encode an image region.
    The said encoder has at least two filters (365, 344) to perform in-loop
    filtering to respectively reduce at least a 1st and a 2nd type of quantisation

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    artifact.

    45. The claim 1 of IN’108 is reproduced as follows:

    “We Claim:

    1. A method comprising:

    encoding an image region, wherein the encoding includes performing in-
    loop filtering to reduce at least a first and a second type of coding
    artifact using at least two filters in succession, the at least two filters
    including a deblocking filter for performing a first pass to reduce
    blocking artifacts and an adaptive sparse de-noising filter for performing
    a second pass to reduce noise, wherein the adaptive sparse de-noising
    filter is selectively enabled or disabled at a given level, the given level
    being at least a macroblock level, a slice level, a picture level or a
    sequence level.”

    46. The Plaintiffs in their arguments have also made submissions regarding
    the status of the corresponding patents of the Suit Patents in foreign
    jurisdictions. It may be important to note that in Philips v Oplus, at para 26,
    the Court observed that even if the validity of one patent is made out, a prima
    facie case in respect of validity generally is taken to have been established.

    47. The Plaintiffs have cited and relied upon the Case No: HP-2019-
    000032, Neutral Citation Number: [2021] EWHC 2152 (Pat). This trial
    concerns European Patent (UK) No. 2 485 558. The UK High Court, the
    European Counterpart EP 2 485 558 has been held to be valid, essential and
    infringed by the Lenovo Group. The Court under paragraphs 297 and 298
    held as follows:

    “Infringement

    297. No separate issue arose in respect of infringement. Lenovo uses LTE
    and therefore infringes the Patent.

    Conclusion

    298. The Patent is valid, essential to Release 8 of LTE and is infringed.
    InterDigital’s conditional application to amend the Patent falls away.”

    48. Thereafter, in appeal bearing Case No: CA-2021-003431 decided on
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    19.01.2023, the UK Court of Appeals upheld the validity of European Patent
    (UK) No. 2485558 which corresponds to the Indian Patent No. 313036
    (IN’036 patent). This suit is between InterDigital Technology Corporation &
    Ors as Claimants/ Respondent and Lenovo Group Ltd & Ors. as
    Defendants/Appellants. The matter was decided by the Royal Courts of
    Justice, Strand, London, WC2A 2LL on 19/01/2023. This appeal relates to
    patent EP (UK) 2 485 558, which is titled “Method and apparatus for
    providing and utilising a non-contention-based channel in a wireless
    communications system”. The relevant paragraphs are reproduced as follows:

    “Lord Justice Birss :

    1. This appeal relates to patent EP (UK) 2 485 558 entitled “Method and
    apparatus for providing and utilizing a non-contention-based channel in a
    wireless communications system” and claiming priority from January 2006.

    The patent belongs to the respondents (“InterDigital”), who contend it is
    essential to the 4G/LTE standard. The patent forms part of a portfolio of
    InterDigital patents said to be essential to various telecoms standards (so
    called Standard Essential Patents or SEPs). In the proceedings InterDigital
    contend that the appellants (“Lenovo”) infringe the patents and ought to take
    a FRAND licence under the portfolio. The overall dispute was managed into
    a series of technical trials dealing with individual patents and a separate
    FRAND trial to identify the licence terms. The validity and essentiality of this
    patent was addressed in the judgment of HHJ Hacon sitting as a judge of the
    Patents Court dated 29 July 2021 ([2021] EWHC 2152 (Pat)) following a
    trial in March 2021. The trial was the first technical trial.

    2…..The judge decided that the patent was essential and rejected all the
    various challenges to validity. The amendment would have added matter, but
    was not necessary. The only case pursued on appeal is obviousness over
    Samsung.

    3. Permission to appeal was given by Arnold LJ, who remarked in doing so
    that although he was satisfied Lenovo’s grounds had a real as opposed to
    fanciful prospect of success, nevertheless they faced an uphill task on this
    appeal.

    The appeal overall

    82. I have been through the grounds of appeal individually and rejected
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    them. Standing back and looking at the judge’s conclusions rejecting
    Lenovo’s case of obviousness, they are conclusions amply supported by the
    evidence, involving no error with which this court could interfere and the
    judge reached a result which was well within the range of outcomes open to
    him. I would dismiss this appeal. There is no need to consider the
    respondent’s notice.”

    49. In another proceeding between IDC and Lenovo, the UK Court of
    Appeal in Case No: CA-2022-001060 upheld the decision on the essentiality
    and infringement of the counterpart of the suit patent IN’910 by the decision
    dated 09.02.2023. For clarity, relevant paras are reproduced as follows:

    “Essentiality and infringement

    86.⁠ ⁠My conclusion as to construction does not affect the judge’s decision
    that the claims are essential and infringed. The only relevant non-
    essentiality and non-infringement issue before the judge was the temporal
    issue I have considered in the context of paragraphs 1 and 3 of Lenovo’s
    respondents’ notice. Counsel for Lenovo submitted that the judge had not
    decided whether the claims were essential and infringed on the
    construction advanced by Inter Digital in this Court. I disagree. So far as
    is material to essentiality/infringement there is no difference between the
    judge’s construction and the construction I have adopted.

    Novelty

    87.⁠ ⁠The judge rejected Lenovo’s first case because Fihatrault did not
    disclose step 2 on the right-hand side of X3, that is to say, it did not
    disclose selecting the next smaller E-TFC for use as a multiplexing limit.
    He nevertheless held the claims lacked novelty over Filiatrault because
    DXX/14 showed that, with certain MAC-d PDU sizes and grants,
    Filiatrault produced the result required by integer IF

    88.⁠ ⁠In my judgment the judge was mistaken about this. It appears that he
    was beguiled by a sleight of hand in the cross-examination of Mr
    Townend. As counsel for InterDigital pointed out, the key question was
    whether “the UE would limit the amount of MAC-d.”

    50. This Court also notes that the US counterparts of the suit patent IN
    313036, which is US 8619747 and US 9203580, were challenged in an inter
    partes review before the US Patents and Appeals Office. The said petition was
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    denied.

    51. This Court also notes that the corresponding patent application of the
    IN’182 patent in China, CN 200880003644.9, was maintained as valid in a
    decision of the National Intellectual Property Administration, PRC, dated
    3.12.2019.

    52. It may also be of some relevance to note that in an inter party decision
    dated 25.03.2026 in a lawsuit filed by the plaintiffs, the Court of Justice,
    Judicial District of the Capital, 3rd Business Court, Brazil in Case
    No.3014729-98.2025.8.19.0001, two of the corresponding/counterpart
    patents which are PI10716323 corresponding to IN’773 and PI0706896
    corresponding to In’036 of the suit patents were held essential and valid.

    53. At the risk of repetition, this Court must note that the foreign Court
    decisions have been alluded to only as aligning aspects to the observations
    made by this Court. That too, only for the purposes of arriving at a holistic
    and just decision on the relief of pro tem security deposit.

    54. Ergo, predicated on the above discussion, this Court, at this stage, is of
    the prima facie view that the plaintiffs have established the validity of the Suit
    Patents.

    ESSENTIALITY

    55. The European Telecommunication Standard Institute (ETSI) is a
    leading SDO for the Information and Communication Technology (ICT)
    sector, which provides a consensus-driven platform for its members to work
    together towards producing Standards and Technical Specifications for
    enabling global interoperability of ICT systems and services. ETSI and its
    members, in collaboration with the International Third Generation Partnership
    Project (3GPP), are involved in developing 3G / 4G / 5G mobile
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    communications standards. ETSI’s standardisation activities can be gleaned
    from its official website, which is www.etsi.org.

    56. As submitted by the plaintiffs, this court also notes that the plaintiffs
    have filed invention disclosures relating to the claimed inventions under IN
    295912, IN 313036, IN 320182 and IN 319673 before the SSO. Further, the
    invention declaration, in respect of the following suit patents, is also filed by
    the plaintiffs before the SSO, ETSI/3GPP.

    57. Apart from the above, during the course of hearing the plaintiffs had
    handed over the Bench, certain test reports claimed to have been generated by
    an institute by the name DEKRA Testing and Certification S.A.U. For

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    convenience, the said test results for Techno Pova 6 Neo is extracted
    hereunder:

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    58. The aforesaid reports purport to have compiled 3GPP conformance
    results of the technical tests and analysis claimed to have been conducted on
    the products of Tecno and Itel devices which are alleged to implement the
    cellular standards and are subject matter of the suit patents, namely, (i) Tecno
    Pova 6 Neo, (ii) Itel Color Pro 5G, (iii) Infinix Note 50X and (iv) Tecno Spark
    Go1. The plaintiffs claim that the aforesaid test reports corroborate that the
    said devices not only conform to the 3G, 4G and 5G standards but also
    implement the suit patents as set by ETSI/3GPP.

    59. Further, as per the submissions of the plaintiffs, at least one claim of the
    suit patent maps and directly corresponds to a specific portion of a standard,
    and therefore the patent is essential to said standard. The plaintiffs have
    placed on record the Essentiality Analysis of its Claims of IN 036. The same
    reads thus:

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    60. As discussed above, the UK counterpart (EP 2 485 558 B1) of the
    Indian Patent which is the Suit Patent, namely, IN 313036 was upheld by the
    UK High Court, and in an appeal thereagainst, the UK Court of Appeals has
    upheld the essentiality and validity of the UK counterpart.

    61. Though the test reports generated by DEKRA are yet to be tested for
    their probative value in accordance with law, however, in the opinion of this
    Court, for the purposes of prima facie finding that the claim charts of the suit
    patents, forming part of the SEP portfolio, map on to the technical
    specifications provided by the defendants of their devices, such test reports,
    constitute sufficient material. Of course, the defendants shall have all rights
    reserved to question and challenge the test report in accordance with law.
    However, for the purposes of the Court to pass necessary orders for deposit of
    pro tem security, the said test reports may prima facie validate the plaintiffs’
    claim on that account. It is made clear that this Court has not given any
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    definitive conclusion one way or the other as to the correctness or probative
    value of the test reports. It has to be borne in mind that the issue of essentiality
    apart from the aforesaid observations has also been upheld by foreign Courts
    as mentioned in the aforesaid paragraphs. Though, the findings and the
    conclusions reached by the foreign Courts may not be binding precedents,
    however, at the stage of considering interim arrangements of deposit of pro
    tem security, the rationale in such judgments/decisions can be considered and
    appreciated, provided this Court is satisfied about the existence of other
    factors. In other words, this Court finds reiteration of its own prima facie
    observations from the observations made in the foreign decisions.

    62. Having regard to the aforesaid discussions, this Court is of the view that
    the plaintiffs have been able to, prima facie, also establish the essentiality of
    the Suit Patents based on the documents placed on record by the Plaintiffs.

    63. So far as the issue of infringement is concerned, this Court is clearly of
    the opinion that the said issue cannot be considered in a summary manner in
    which the opinion on validity and essentiality has been prima facie, formed. In
    this context, it would be relevant to recall the observations of the learned
    Division Bench in Intex Technologies where the four fold tests propounded by
    the learned Single Judge in Nokia vs. Oppo was essentially not accepted. In
    fact, it was also observed that in case the said four fold tests is insisted upon,
    it would cast an onerous burden upon the SEP holders and that too at the
    interim stage itself.

    Pre-suit correspondences between the parties

    64. The parties in the present case were ad idem that there were numerous
    meetings held to discuss the technical and commercial aspects of the SEP
    portfolio of the plaintiffs in respect of 3G, 4G, 5G and LTE technologies. It is
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    not disputed that the parties have been in constant negotiations since the year
    2019. Equally, it is undisputed that the plaintiffs had furnished to the
    defendant no.1, claim charts of atleast 100 claims which according to it form
    part of its entire portfolio. The parties are also not at dispute that in respect of
    50 such claims, defendant no.1 has carried out technical analysis and
    verifications. It is also admitted by the parties that the said negotiations are
    still continuing. However, the plaintiffs and the defendants rely upon certain
    correspondences which may be relevant for this Court to consider in order to
    assess whether the plaintiffs was a willing licensor or offering well defined
    and reasonable FRAND terms. Similarly, the correspondences may reflect the
    intention of the defendants whether it was a willing licensee. In order to
    appreciate the overall factors, it is found relevant to extract hereunder the
    following correspondences exchanged between the parties. The emails dated
    19.03.2024, 29.03.2024, 02.08.2024, 09.12.2024, 23.12.2024, 26.12.2024 and
    03.07.2025 read thus:

    沈 胡 文

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    胡 文 程

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    3.

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    65. This court also notes that, during the technical discussion, at least three
    of the suit patents were discussed during the negotiations before filing the
    present suit.

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    66. Further, DB of this court in Intex v Ericsson (supra), while rejecting
    the views of Nokia v OPPO (SB) (supra) emphasised that, to grant the pro
    tem in favor of the plaintiffs, there is no need show an unequivocal admission
    with respect to following four factors including that the royalty rate proposed
    by the Plaintiffs were FRAND:

    “114. Further, the learned Single Judge in Nokia Vs. Oppo (supra) has set an
    impossibly high bar for admission in a case of Standard Essential Patent
    FRAND infringement, i.e., there has to be an unequivocal admission on (i)
    essentiality and validity of the suit patents (ii) fact of utilization (iii) fact that
    such utilization, absent payment of liability would amount to infringement (iv)
    that the royalty rate proposed by the Plaintiff was FRAND. If there was an
    unequivocal admission on all four counts, there would be no necessity to file a
    suit for infringement at all and otherwise also, same would mean
    seeking/passing of a final decree at the interim stage!

    115. In the opinion of this Court, the four-fold test casts an onerous burden
    upon the Standard Essential Patentee and that too at the interim stage itself.
    In fact, the said burden is completely alien to the patent jurisdiction and does
    not apply even in normal patent suits.”

    [emphasis supplied]

    67. From the aforesaid, it can be inferred that the defendant no.1 has shown
    its willingness to obtain license of the SEP portfolio, of course on FRAND
    terms and has, though resisted the offer made by the plaintiffs at its program
    rates, given three counter offers, the third one being higher than the
    second counter offer. Even if this Court were to take note of the argument that
    these are not admissions and are offers without prejudice to their rights, at this
    stage, having regard to the correspondences exchanged, may be a relevant
    consideration for the purposes of balancing equities and passing orders for a
    reasonable pro tem deposit to secure the interest of the plaintiffs.

    68. That said, much was argued on the purported precarious financial
    condition of the defendants and that there is a criminal proceeding by the
    Enforcement Directorate whereby the bank account of defendant no.1 was
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    frozen. However, learned counsel for the defendants contended that all the
    defendants are in pink financial health and there is no economic financial
    distress any of the defendants are facing. This Court finds that the plaintiffs
    have given certain details, basis whereof, it is apprehending financial distress
    so far as the defendants are concerned. To the said details the defendants have
    rebutted in an omnibus manner and have answered only with respect to the
    ED proceeding and that all the defendants have robust financial health.

    69. Be that as it may, in the considered opinion of this Court while a
    precarious financial condition of the defendants may be a factor propelling the
    Court to pass orders for deposit of pro tem security, however, if the ultimate
    considerations for the deposit of pro tem security is to balance equities and
    ensure security to the plaintiffs, the financial condition may be one of the
    factors only and not the only factor. Thus, looked at any which way, the
    financial condition of the defendants are claimed to be robust, which actually
    propels this Court to presume that the defendants shall have no qualms in
    making a pro tem deposit since the same acts in tandem to provide security to
    the plaintiffs.

    70. The correspondence referred to above coupled with the fact that the
    defendants have indeed made counter offers and simultaneously extending to
    demonstrate its willingness, can be a relevant consideration for the purpose of
    pro tem security deposit. Essentially, this is so because, while an implementer
    continues to sell its devices without any restraint, which may possibly be
    functioning on the 3G, 4G, 5G technologies comprising the SEP portfolio of
    the plaintiffs, apparently it is the plaintiffs which is being put to some
    financial distress and loss. The overall consideration of the correspondence
    exchanged between the parties gives an impression that on the one hand the
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    defendant no.1 claims to be ready and willing to obtain necessary license,
    while on the other, the negotiation is getting delayed for one reason or the
    other. Although, the delay may not necessarily be fully attributable to the
    defendant no.1, however, is indeed resulting in financial loss to the plaintiffs.
    Moreover, during the period of negotiations, defendant no.1 has not secured
    the financial interests of the plaintiffs despite showing willingness. Thus, the
    need to balance equities. It cannot be fathomed that a party can continue to
    sell its products; continue negotiations; continue technical evaluation of the
    claims; not provide any security to the SEP holder; not disclose the alternate
    technology that might be used in its products; not demonstrate how the
    technologies are being used without infringing the standards and SEP
    portfolio, and still insist that there is no requirement for the Court to pass
    orders for deposit of pro tem security. In the understanding of this Court, the
    words “interim arrangement” and “balance of equities” as used by the learned
    Division Bench of this Court in the aforesaid judgments are based on
    equitable consideration of factors in respect of both the parties.

    71. Another consideration which would be relevant is the non filing of the
    TPLAs by the plaintiffs. However, it is also significant to note that on its part
    even the defendant no.1 did not disclose to the plaintiffs the annual sales of its
    products in India. In the opinion of this Court, had the defendants disclosed its
    sales in India, that too, in view of the NDA between both the parties, it is
    probable that the plaintiffs may have been able to offer FRAND terms which
    may be acceptable to the defendants. Though the plaintiffs did not disclose the
    TPLA terms to the defendants or to this Court, however, the e-mails dated
    03.07.2025 and 25.08.2025 did indeed refer to certain public figures arrived at
    between the plaintiffs and third parties which could have been ascertained by
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    the defendant no.1. The defendant no.1 being in the commercial sphere surely
    cannot feign ignorance of how to assess or ascertain the figures relevant to it,
    while negotiating FRAND terms. Thus, this Court is unable to appreciate the
    contention of the defendants that no orders for pro tem security deposit can be
    made unless the plaintiffs furnishes TPLAs and is made accessible either to
    the Court or the defendant no.1. The said submission is unmerited.

    72. That apart, the question as to whether TPLAs are required to determine
    the pro tem quantum is no more res integra. The learned Division Bench of
    this Court in Nokia vs. Oppo (supra) held as under:

    “NON-FURNISHING OF COMPARABLE PLAs IS IRRELEVANT AT THIS
    STAGE

    88. As regards non-furnishing of comparable PLAs is concerned, this
    Court is of the view that the said issue is irrelevant as the Court is not
    directing Oppo to pay the FRAND rate at this stage. Even the learned
    Single Judge has not held that Nokia ought to have supplied its PLAs to
    Oppo.”

    [emphasis supplied]

    73. Additionally, this view was reiterated by a single bench of this court in
    Dolby vs Lava (supra) the said opinion was echoed in the following manner:

    “27. The Division Bench specifically held that non-furnishing of the
    comparable third-party license agreements is irrelevant as the Court, at
    the stage of determining the pro tem deposit, is not determining FRAND
    rate. The relevant paragraph is set out below: –

    “88. As regards non-furnishing of comparable PLAs is concerned,
    this Court is of the view that the said issue is irrelevant as the Court
    is not directing Oppo to pay the FRAND rate at this stage. Even the
    learned Single Judge has noted held that Nokia ought to have
    supplied its PLAs to Oppo.””

    **** **** ****

    38. From an analysis of the aforesaid judgements passed by the Division
    Benches of this Court in Intex v. Ericsson (supra), Nokia v. Oppo (supra)
    and Guangdong Oppo v. Interdigital Technology (supra), the following
    legal principles can be culled out: –

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    I. The SEP cases are different from normal patent infringement cases to the
    extent that an SEP holder does not have the right to claim an injunction
    against an implementor without holding negotiations with the implementor,
    as per the FRAND protocol;

    II. Indian courts are empowered to pass a direction for a pro tem deposit,
    and this power can be exercised under Section 151 of the CPC, without
    filing a separate application for the same;

    III. Pro tem orders are in the nature of ad-interim orders, which operate
    till the time an application for interim injunction is decided by the Court;
    IV. Pro tem deposits are granted to balance the SEP holders’ right to
    receive value for the use of their technology with the implementor’s right to
    contest the patent. This ensures that the implementor does not unfairly
    benefit from the use of patented technology during the course of a
    potentially lengthy litigation, where the issues such as validity, essentiality
    and FRAND terms have to be determined;

    V. Normally speaking, a pro tem order should be directed only after a
    prima facie finding on essentiality and validity of the suit patents.
    However, for passing pro tem orders, no detailed exploration of merits of
    the case is required, as is required for purposes of grant of an interim
    injunction;

    VI. The four-fold test laid down by the Single Bench in Nokia v. Oppo
    (supra) would not apply for purposes of grant of a pro tem order;

    VII. The Court can form a prima facie view based on surrounding factors.
    Where the Court is of the view that the challenge to essentiality and
    validity of the SEP is merely an afterthought, it would be a relevant factor
    in determining the question of prima facie essentiality and validity of the
    suit patents. Therefore, determination of pro tem would depend upon the
    facts and circumstances of a case;

    VIII. Conduct of the parties during negotiations is one of the key factors to
    be kept in mind while determining whether a potential licensor and
    licensee were willing licensors or willing licensees, respectively. An
    unwilling licensee cannot be permitted to freely sell its devices using the
    SEPs of the patent owner, without making a pro tem security deposit;
    IX. There is no requirement for the patent owner to furnish any third
    party licensing agreements to the implementor at the stage of
    negotiations or at the stage of determining pro tem deposit.

    **** **** ****

    47. From an analysis of the aforesaid correspondence exchanged
    between the parties, the following aspects can be discerned:

    …..-vii. Lava kept on insisting that Dolby should provide third-party
    confidential licensing agreements to Lava, which was unjustified….

    [emphasis supplied]
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    74. Thus, the overwhelming law in this regard is against any mandatory
    requirement for the plaintiffs to furnish TPLAs, particularly at the stage of
    consideration of pro tem deposit. This Court is also of the considered opinion
    that furnishing of TPLAs may obviate a delayed or protracted trial and bring
    the disputes to a closure. It is possible that in certain cases the Court may, if it
    is of the opinion that such documents are required, direct the parties to
    produce TPLAs. The opinion rendered by the learned Division Bench ought
    not to be construed as if it forecloses the power of the Court to direct a party
    to furnish TPLAs if it is of the opinion that to determine the payment of pro
    tem security, such material would be a factor which needs to be considered
    before any such direction is passed.

    75. So far as the argument of Mr. Saikrishna Rajagopal that 4 out of 5 suit
    patents have been held to be invalid by Supreme Court of China is concerned,
    the chart furnished by Mr. Saikrishna Rajagopal very fairly also disclosed that
    other foreign courts in countries like USA, UK and Germany, have upheld
    either the validity or the essentiality or in certain cases, both, of the respective
    counterparts of some of the suit patents. Though no doubt one foreign Court
    may have invalided certain suit patents, however, largely, globally different
    courts of different jurisdiction appear to be in alignment with the finding, even
    if prima facie, that the counterparts of some of the suit patents are either
    essential or valid or both. Notwithstanding the prima facie finding of this
    Court on essentiality and validity, if one were to take the general analysis or
    average of the foreign courts, it cannot be concluded with conviction that the
    suit patents are invalid or not essential to the standards. Therefore, the
    argument in this context may be a factor, however, having regard to other
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    decisions of foreign courts favouring the plaintiffs, is unpersuasive and
    unmerited.

    76. As held in Nokia vs OPPO DB (supra) and discussed earlier that
    granting pro tem security does not confer any advantage to the licensor/SEP
    holder, rather, it only balances the asymmetric advantage that an implementor
    has over a SEP holder. For better clarity, the relevant para is reproduced as
    follow:

    “A PRO-TEM SECURITY ORDER CANNOT BE LIKENED TO AN
    INJUNCTION

    59. This Court is further of the opinion that a pro-tem security order
    cannot be likened to an injunction order because unlike an injunction order
    it does not stop or prevent the manufacturing and sale of the infringing
    devices. The intent of a pro-tem security order is to either ensure
    maintenance of status-quo or to retain the Courts’ power and ability to
    pass appropriate relief at the time of disposal of the injunction
    application under Order XXXIX Rules 1 and 2 or at the final stage. In
    the facts of the present case, the pro-tem security order does not confer
    any advantage upon Nokia as it only balances the asymmetric advantage
    that an implementer has over a Standard Essential Patent holder. This
    Court in Intex vs. Ericsson (supra) has held as under:-

    “72. Further, the implementor has to either accept the licensor’s
    offer or give a counter offer along with an appropriate security in
    accordance therewith to prove its bonafides as in the
    interregnum it cannot freely sell its devices using such Standard
    Essential Patents. If no ad-hoc royalty is paid during the
    interregnum, such party benefits, to the disadvantage of other
    willing licensees, and gets an unfair competitive edge in the
    market.””

    [emphasis supplied]

    77. Further, this Court also notes that the plaintiffs have executed more
    than 50 licenses for their telecommunication SEP portfolio, which are
    worldwide in scope and also cover India. Many companies such as Apple,
    Google, Oppo, Vivo, Samsung, Huawei, Lenovo, LG, Sony, Xiaomi, ZTE,

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    HTC, Kyocera, have entered into agreements to license plaintiffs’ portfolios
    of SEPs relating to telecommunications, which include the Suit Patents.

    78. Additionally, this court also notes that the plaintiffs have enforced the
    suit patent against third parties in Interdigital Technology Corporation &
    Ors. vs Guangdong OPPO Mobile Telecommunications Corp. Ltd. & Ors.,
    CS(COMM
    ) 692/2021, and Interdigital VC Holdings Inc & Ors. Vs
    Guangdong OPPO Mobile Telecommunications Corp. Ltd & Ors.,
    CS(COMM
    ) 707/2021. In CS(COM) 692/2021, the court, in the said
    proceedings directed the OPPO to furnish a Bank Guarantee with this
    Hon’ble Court as pro-tem security. It is important to note that all 5 suit patents
    in question in CS(COM) 692/2021, while in CS(COMM) 707/2021, the suit
    patent IN’108 was in question.
    The plaintiffs have also relied on the
    Interdigital Technology Corporation & Ors. vs Xiaomi Corporation &
    Ors., CS(COMM
    ) 295/2020, to support their argument of enforcement of the
    suit patents against third parties. However, this suit examines the trans border
    jurisdiction and anti-enforcement injunction, and does not talk about the
    validity, essentiality, therefore, this court believes that this decision is not
    relevant to rely on at this stage.

    79. In Dolby vs Lava (supra), this Court emphasised that in order to
    balance the equities between the parties, the court has the power to pass a pro-
    tem order being a temporary arrangement without a detailed exploration of
    merits, if the facts so warrant. The Court further emphasized that in order to
    arrive at a prima facie finding regarding the essentiality and validity of the
    patents in question, the court can refer the surrounding factors like “the
    number of licenses entered into by SEP owners in respect of the portfolio of
    SEPs relating to the same technology; enforcement of the said SEPs before
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    competent Courts; pro tem orders passed by the courts relation to the said
    SEPs.” The court noted that these would be relevant factors if it found that
    there are a significant number of competitors/players in the market, including
    those having a better bargaining position on account of their volumes/market
    share, and are paying royalties for such SEPs. For clarity, the relevant
    paragraphs are reproduced hereunder:

    “39. In my considered view, the expression, used by the Division Bench in
    Nokia v. Oppo (supra) in paragraph 81, “Normally speaking, a pro-tem deposit
    should be directed only after a prima facie finding of essentiality and validity of
    the suit patents has been recorded” has to be reconciled with the observations
    made in paragraph 58 that “Consequently, to balance the equities between the
    parties, this Court has the power, if the facts so warrant, to pass a pro-tem
    order being a temporary arrangement without a detailed exploration of
    merits.”. Therefore, even though the Court is required to give a prima facie
    finding of essentiality and validity of the suit patents, the level of scrutiny would
    depend upon the facts and circumstances of the case. Where the conduct and
    actions of the implementor during the negotiations stage indicates no serious
    challenge to the essentiality and validity of the suit patents, the Courts may not
    get into a detailed exploration of merits. To arrive at a prima facie finding with
    regard to the essentiality and validity of the suit patents the Court can look at
    the surrounding factors such as the number of licenses entered into by SEP
    owners in respect of the portfolio of SEPs relating to the same technology;
    enforcement of the said SEPs before competent Courts; pro tem orders passed
    by the courts relation to the said SEPs. Where it is found that a significant
    number of competitors and players in the market, including entities that are in a
    better bargaining position on account of their volumes or market share, are
    paying royalties for such SEPs, it would be a relevant factor.

    40. If in every case the Court were to conduct an in-depth examination of issues
    relating to the essentiality and validity of the suit patents, the whole objective
    behind a pro tem deposit would be defeated. Judicial notice can be taken of the
    fact that once in litigation, the implementors take all possible defences relating
    to essentiality, validity and non-infringement even though these have not been
    raised during the negotiations. Therefore, in my considered view, the
    determination of pro tem deposit has to be very factcentric. In cases where the
    implementor has not made a credible challenge to the essentiality and validity
    of the suit patent during the negotiations stage and makes a challenge only
    during the litigation as an afterthought, the Court can look at the surrounding
    factors to determine prima facie validity and essentiality of the suit patents.
    Otherwise, the threshold for deciding a pro tem deposit would become the same
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    as that for deciding an interim injunction application. This is not to say that the
    Court does not have to examine the aspects of validity and essentiality of the
    suit patents at all.”

    80. Learned counsel for the defendants had also argued that having regard
    to the protection conferred upon the patentees under section 48 of the patents
    Act, 1970, the said protection can extend only to those patents which are
    registered under the Indian law. In other words, and without admitting to the
    validity and essentiality of the suit patents, evaluation of pro tem security can
    be based only on those patents which are registered in India and not the entire
    SEP portfolio of the plaintiffs containing other patents as well.

    81. Though, the said argument appears to be attractive and logical,
    however, in view of the peculiar manner in which the 3G, 4G and 5G
    technologies work, the assessment and quantification of pro tem security
    cannot be compartmentalised and insulated from other patents forming part of
    the SEP portfolio. From what has been argued and shown to this Court, it
    appears that the technologies are so well enmeshed, entrenched, interwoven,
    intertwined and interdependent that even if one of the minor or trivial
    technologies or aspects are ignored or overlooked or taken away from the
    entire, the technology might fail or not work at its optimum best. How one
    patent and its process is inter linked and intrinsically connected or dependent
    with another, cannot be gauged or ascertained with certainty. Thus, to expect
    eschewing of suit patents from the rest of the SEP portfolio, though may be an
    academic exercise, but far from reality. Law cannot be applied de hors reality.
    Moreover, the parties, in their correspondence have nowhere negotiated prices
    or rates etc on patent to patent basis, or a country specific patent manner, but
    the entire portfolio. It is apparent that the parties are clear on how the
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    technologies work. Thus, such an argument cannot be appreciated.
    QUANTIFICATION OF PRO TEM DEPOSIT:

    82. As noted above, the plaintiffs have not placed on record TPLAs nor
    have the defendants placed record of its sales of the mobile smartphones. That
    however, would not mean that the Court is at some disadvantage from passing
    an order directing deposit of pro tem security as there are other relevant
    considerations available.

    83. The plaintiffs had given its first offer at for the
    period against which the defendants had given its first counter
    offer at . It appears after further negotiations that the
    plaintiffs have revised its offer to for the period of
    years as noted above, against which the defendant no.1 gave its enhanced
    counter offer at . Further negotiations resulted in the
    defendant no.1 giving its third enhanced counter offer of
    .

    84. It is clear from the aforesaid that the gap between both the offers and
    counter offers is very wide and thus, there cannot be a mid way between the
    two. In the absence of any TPLA, it is difficult to quantify the pro tem
    security. In such circumstances, it would be in alignment with the aforesaid
    observations and analysis that the quantification can be ascertained from the
    counter offer made by defendant no.1.

    85. It is pertinent to note that the third counter offer dated 20.09.2025 of
    is an enhancement to the extent of of the second
    counter offer which was pegged at . A perusal of the
    written statement indicates that the defendants had not furnished any details
    with regard to any alternate technology that might have been used in the
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    products, which appears to be in contravention of Rule 2(f) of the High Court
    of Delhi Rules Governing Patent Suits 2022. Equally, the written statement
    does not appear to be specific in terms of the requirement of Rule 2(d) and
    Rule 3B(ii) & (vi) of the Rules, 2022.

    86. Learned counsel for defendant no.1 had, without prejudice to the rights
    and contentions of defendant no.1 submitted two options to satisfy the pro tem
    security. One of such options was based on the economic expert’s report of
    the defendant no.1 offering in respect of the cellular suit
    patent and in respect of the HEVC Suit Patents from the
    date of filing of the suit. The other option was an offer of a bank guarantee for
    an amount equivalent to of the last counter offer of
    made by the defendants.

    87. Since the counter offer of was on an annual basis, the
    period for which the plaintiffs have sought execution of FRAND agreement
    being the years , the cumulative total for this period would
    approximately be more than . As such, it appears to this Court
    it would be fair and in the interests of justice to direct the defendants to
    deposit 1/5th of which comes to . The
    deposit so directed has to be calculated in INR as per the exchange rate
    prevailing as on date.

    88. Accordingly, the following directions are passed:

    (a) The defendants shall deposit a sum of or the
    equivalent in Indian Rupees with the Registrar General of this Court
    within a period of eight weeks from date. The said sum shall be kept in
    an interest bearing FDR in the name of the Registrar General, with
    auto renewal mode.

    Signature Not Verified
    Digitally Signed
    By:YASHRAJ CS(COMM) 1045/2025 & 1046/2025 Page 99 of 100
    Signing Date:03.07.2026
    12:05:35

    (b) In the alternate, the defendants would be at liberty to submit an
    unconditional bank guarantee for a sum of or the
    equivalent in Indian Rupees to the satisfaction of the Registrar General
    of this Court within the same period as noted in direction (a) above.

    89. It is made clear that the observations and analysis made hereinabove
    shall not tantamount to any final expression on merits.

    90. The applications are disposed of accordingly.

    91. Parties are at liberty to apply for unredacted copy of this order, which
    may be furnished forthwith.

    CS (COMM) 1045/2025 and CS (COMM) 1046/2025

    92. List on 24.08.2026, the date already fixed.

    93. Copy of the order be given Dasti under the signature of Court Master to
    both the parties.

    TUSHAR RAO GEDELA
    (JUDGE)
    JULY 01, 2026/lr/ak

    Signature Not Verified
    Digitally Signed
    By:YASHRAJ CS(COMM) 1045/2025 & 1046/2025 Page 100 of 100
    Signing Date:03.07.2026
    12:05:35



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