In T 392/97 the board ruled that the subsequent appointment of oral proceedings by a national patent court to take place on the same date as the previously appointed oral proceedings before the board was not in itself a sufficient reason for adjournment.

In T 228/09 the board considered, having regard to Art. 2.2 of the 2007 Notice, that unforeseen infringement proceedings could not generally be regarded as an acceptable ground for adjournment.