<Germany is the first to patent, so prior art is not as big an issue there>

Ah, you are correct, unfortunately. And after reading further, I get the impression that the scope of the investigation may lie only within the facts presented by the nullity requestor. Not sure about that, but in any case, it does not look like they beat the bushes looking for prior art on their own, as the examiners at the USPTO do. Thanks

Opty