Chinese ASI again targets European IP enforcement, prompting Dutch AASI backed by penalties of up to €100 million

Context: 

• China’s use of anti-suit injunctions (ASIs) in standard-essential patent (SEP) disputes sparked controversy over the extraterritorial reach of its courts and led to an EU complaint at the World Trade Organization (WTO). The dispute culminated in China announcing the withdrawal of its ASI policy in SEP disputes, with the Supreme People’s Court (SPC) adding the qualification “to the extent that it ever existed” (April 6, 2026 ip fray article).
• China’s ASI orders came in a concentrated burst between August and December 2020. Their scope expanded from restrictions on enforcing injunctions already granted (Huawei v. Conversant and ZTE v. Conversant) to restrictions on bringing new infringement suits outside China (OPPO v. Sharp), seeking or enforcing injunctions and pursuing parallel rate-setting proceedings worldwide (Xiaomi v. InterDigital), and even pre-emptively seeking to prevent anti-anti-suit injunctions (AASIs), as in Samsung v. Ericsson. That wave then came to an abrupt halt: Shenzhen rejected Lenovo’s ASI application against Nokia in January 2021, and no further Chinese ASIs in SEP disputes have been publicly reported.