In recent years, the United Kingdom has issued injunctions in several transnational standard-essential patent litigations, making injunctions a hot topic in judicial practice. The injunction system originated in the early courts of equity in England and was expanded and applied to transnational civil fields in the 19th century. The issuance of injunctions in the UK is subject to a number of restrictive factors, such as jurisdiction, international comity, and likelihood of success. China has a late start in the practice of injunctions, and its position is unclear; it can draw on the relevant system of the United Kingdom to set up an independent injunction system based on the behavioural preservation system.

Quanzhen Ruan. A Study of Anti-Injunctions in Standard Essential Patent Disputes in the United Kingdom. International Journal of Frontiers in Sociology (2023), Vol. 5, Issue 16: 66-73. https://doi.org/10.25236/IJFS.2023.051611.

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