Networld Sports Limited v Quick Play Sport Limited

On an appeal from the UKIPO, the court conducts a review and gives respect to the specialist tribunal’s decision. A claim must be construed as a whole, in the light of the patent’s description and drawings. An integer requiring frame connection points to be biased laterally apart concerns the frame’s restoring bias, rather than merely the forces experienced by the assembled product. A pliable crossbar is supported in tension only where tension is applied to it by the frame; tension caused solely by the crossbar’s own weight is insufficient. Applying those principles, the prior art did not disclose the relevant integers, so the claims remained novel.

Networld appealed from the UKIPO Hearing Officer’s decision, numbered BL O/0957/25 and dated 14 October 2025, concerning an application under section 72(1) of the Patents Act 1977 to revoke Quick Play’s patent for a portable sports goal.

The Hearing Officer held claims 11 and 15 invalid for lack of novelty, but rejected the application concerning claims 1 and 10. The appeal concerned the construction of integers requiring the frame’s upper connection points to be biased apart and to support a pliable crossbar in tension. Quick Play also served a Respondent’s Notice advancing an additional ground of anticipation.

1. Appeal dismissed. The appeal was a review of the UKIPO’s decision. Respect was owed to the specialist tribunal. The court found no error of principle or plainly wrong conclusion in the Hearing Officer’s reasoning.
2. The relevant claim language had to be construed as a whole, in the light of the patent’s description and figures, applying the principles in Virgin Atlantic Airways Limited v Premium Aircraft Interiors UK Limited [2009] EWCA Civ 1062. The expression requiring the upper frame connection points to be biased laterally apart referred to the restoring bias of the frame. It meant that the frame’s reaction forces against the connected net would tend to move the connection points apart. It did not refer merely to the biasing force experienced by the assembled product.
3. On that construction, D1 did not disclose the relevant feature. Its poles were bent from positions within the base footprint and their bias was to return together, rather than to move the upper connection points apart. Claims 1 and 10 were therefore novel over D1. The appeal concerning claim 10 stood or fell with the appeal concerning claim 1 and was rejected for the same reasons.
4. The Respondent’s Notice was allowed. A pliable crossbar hanging between two fixed points, with tension arising only from its own weight, was not a crossbar which the frame was configured to support in tension. The invention required tension to be applied to the crossbar by the frame, producing structural rigidity in the goalmouth. D1 did not disclose that feature and therefore did not anticipate claim 1 on this additional basis.
5. The court also considered the guidance on appellate economy in Unik Bond SA v Catbalogan Holdings SaRL [2025] EWCA Civ 1594, permitting adoption of a sound decision below without repeating its reasoning.

• High Court (Patents Court): The appeal from the UKIPO was dismissed. The Respondent’s Notice was allowed.
• UK Intellectual Property Office: In BL O/0957/25, dated 14 October 2025, the Hearing Officer held claims 11 and 15 invalid for lack of novelty but rejected the revocation application concerning claims 1 and 10.