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On the quality of IT products: A comment on Ruling No. 307-ES25-7553 of the Supreme Court of the Russian Federation of 19 December 2025 (TS Integratsiya LLC case)

https://doi.org/10.38044/2686-9136-2026-7-2

Abstract

It products are often complex solutions combining hardware, software, and related services, delivered partly through digital means and integrated to serve a single purpose. Russian courts have been extremely cautious in extending the legal regime governing goods to intangible it products, including the application of civil law regulation to product quality and product delivery. Prerequisites for applying a consistent approach can be seen only in the sphere of consumer disputes. Against this background, Ruling of the Supreme Court of the Russian Federation No. 307-ES25-7553 dated 19 December 2025 in case No. 56-4294/2024 deserves particular attention. The case arose from a commercial dispute concerning the B2B supply of a comprehensive it product consisting of a server, software, and digital certificates granting access to technical support services. This commentary examines the distinctive features of the Supreme Court’s position regarding the legal characterization of the contractual relationship, the legal concept of it product quality, and the range of unresolved issues. The analysis employs formal-legal, systemic, and functional methods. The lower courts, relying on the contractual terms, excluded both the technical support certificates and the technical support services from the scope of statutory quality requirements, thereby limiting the application of Articles 469 and 475 of the Russian Civil Code. The Supreme Court, by contrast, endorsed a more functional understanding of the concept of “goods.” Under this approach, the central question concerns the legal nature of the certificates, their role within the entire IT product, and the extent to which the rules governing product quality are applicable to these certificates. The commentary outlines the specific features of applying a purposive (functional) approach to assessing the quality of complex hardware–software systems and highlights the issues associated with allocating contractual responsibilities between vendors (rights holders) and distributors within the supply chain. It is concluded that the Supreme Court’s position will prove significant for disputes involving business purchasers of IT products. The Court demonstrated the willingness to apply a less formal approach, thereby strengthening the remedies available to buyers. However, no comprehensive legal characterization was given, and several fundamental issues remained unresolved.

About the Author

A. A. Dolganin
Lomonosov Moscow State University
Russian Federation

Alexander A. Dolganin — Ph.D. in Law, Associate Professor, Department of Commercial Law and Basics of Legal Method, faculty of law

1, Leninskie Gory St., Moscow, 11999



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ISSN 2686-9136 (Online)