Orange-Book-Standard (Az. KZR 39/06) is a decision issued on May 6, 2009 by the Federal Court of Justice of Germany (German: Bundesgerichtshof, BGH) on the interaction between patent law and technical standards, and more generally between intellectual property law and competition law. The Court held that a defendant, accused of patent infringement and who was not able to obtain a license from the patentee, may defend himself, under certain conditions, by invoking an abuse of a dominant market position.