29 March 2024

T 0293/19 - Departing from Kawasaki Steel (?) - repost

Key points (repost for technical reasons)

  •  "Claim 10 of auxiliary request 6 relates to an IgM preparation obtainable by the process of claim 8 or claim 9, in which at least 15% with respect to the total immunoglobulins is IgM, having a proteolytic activity of less than 8U/l and wherein the process provides a more than 3log10 removal of non-enveloped viruses."
  • "In favour of the appellant-patent proprietor, the following examination assumes that the IgM preparation of claim 10 has less proteolytic activity than the IgM composition of example 3 of D18. The problem of providing an improved IgM preparation is thus considered credibly solved by a preparation having a proteolytic activity below the threshold set by claim 10."
  • "It is known from the prior art that the proteolytic activity of an immunoglobulin preparation should be as low as possible "
  • "There is no effect linked to the threshold set by claim 1, over and above what is known in the prior art, namely that the lower, the better. The prior art teaches using Sephadex columns to reduce it (D6, column 1, lines 44 and 45). A low proteolytic activity would thus have been an obvious option for a skilled person seeking an improved IgM preparation. "
  • "The appellant-patent proprietor argued that the situation in the present case was comparable to that underlying decision T 595/90 [Kawasaki Steel]. There was no process in the prior art which could lead to a product having the required proteolytic activity. Even if said property were to be envisaged as an obvious aim, there was no process at the disposal of the skilled person which could provide said product, which was inventive for this reason alone. "
  • " It is disputable whether other processes known from the prior art could lead to the preparation of a product having a proteolytic activity below the threshold set by claim 1. In favour of the appellant-patent proprietor, the board will nevertheless assume it not to be the case."
  • "The standard for examination of inventive step by the Boards of Appeal is the problem-solution approach. At no point it includes the question of whether a product could or could not be obtained by a process known from the prior art for it to be inventive.

    A product which can be envisaged as an obvious improvement by a skilled person is not necessarily inventive for the reason alone that it cannot be prepared by the methods available at the filing date. The conclusion on this point would necessarily depend on the facts of the case and the claim's wording.

  • In the present case, a low proteolytic activity is known to be advantageous. An IgM having such property is thus an obvious solution to the problem of providing an improvement. Even if at the filing date no process could have led to that product (i.e. the product is novel), the invention resides in developing such process (claim 1), not in the product, at least not in the terms of the distinguishing features chosen by the appellant-patent proprietor."

  • Abolishing T 595/90 would be quite an upheaval. Though, the Board here seems to propose abandoning it. 

EPO 
The link to the decision is provided after the jump.



T 0293/19 - Departing from Kawasaki Steel (?)

For technical reasons, this post was reposted at:

https://justpatentlaw.blogspot.com/2024/03/t-029319-departing-from-kawasaki-steel_29.html 

27 March 2024

T 1879/21 - For inducing smoltification

Key points

  • Claim 1 is directed to "A fish feed for inducing smoltification of Salmonidae"
  • "The patent is concerned with the provision of fish feed that induces smoltification of Salmonidae. This family of fish includes Atlantic salmon and rainbow trout. Salmonids in freshwater which decide to migrate to seawater undergo a physiological process called smoltification. Smolt refers to a salmon fish in freshwater ready for migration to seawater"
  • "To meet the requirements of sufficiency of disclosure, an invention has to be disclosed in a manner sufficiently clear and complete for it to be carried out by the skilled person without undue burden and without needing inventive skill on the basis of the information provided in the patent specification and, possibly, common general knowledge."
  • "Claims 1 and 6 comprise the functional feature "for inducing smoltification of Salmonidae" or "for inducing smoltification in Salmonidae", respectively. In accordance with G 1/03 (Reasons 2.5.2), if an effect forms part of the claimed subject-matter and there is lack of reproducibility of the effect, there is lack of sufficiency of disclosure. For the reasons set out below, the board concludes that the specification does not contain sufficient information on relevant criteria for finding appropriate alternatives over the whole scope of the claims with reasonable effort."
    • I wonder if in claim 1, "for inducing smoltification" is limiting or is, in effect, "suitable for" ? Is it a second medical use claim ? Or can a feature simultaneously be "functional" for Art. 83 and "suitable for" for Art. 54 ?
    • Note, claim 6 as granted is directed to "Use of a fish feed  ...  for inducing smoltification in Salmonidae" which could be a method of treatment claim, if claim 1 is a second medical use claim. 
  • ", the board notes that the statements in declaration D31 from an expert [of the proprietor] and in D66 by the inventor support the view that the relative concentrations of activators/positive modulators and deactivators/negative modulators of PVCRs need to be adjusted (or "tailored") to obtain a non-haphazard and reproducible activation and smoltification."
    • "these statements in D66 were made in a dispute over inventorship and remuneration under Norwegian law"
  • " The board thus agrees with the opponents that the knowledge to carry out the claimed invention is not shared with the public via the patent. By contrast, the statements in D31 and D66 undermine the patent proprietor's assertion that the broad ranges for the positive and negative PVCR modulators provided in the claims were already "tailored" (or optimised) and that thus any ratio of the modulators could be combined to induce smoltification."
  • "Given these considerations and the serious doubts substantiated by verifiable facts, the single example feed of the patent does not have sufficient probative value to show that the invention is operable across the entire scope claimed. Although that feed composition (test diet 2) is in line with the invention as claimed, by itself it is insufficient given that the metal ion content is not specified and the amounts of activator species far exceed the minimum amounts required in claim 1. "
  • The patent is revoked.
EPO 
The link to the decision is provided after the jump, as well as (an extract of) the decision text.


25 March 2024

T 0498/22 - Late filed late-filed objection

Key points

  • The Board, in translation: " The appellant argued for the first time in the oral hearing that auxiliary request 1 should have already been submitted in the first instance [and was therefore inadmissible]." 
  • The Board: " First of all, it should be noted that, according to Article 13(2) RPBA 2020, such a request for non-admission, which was only submitted during the oral hearing, is generally not to be taken into account. The response to the appeal with the auxiliary requests was submitted in August 2022. The summons to the oral hearing with the chamber's preliminary opinion was made in July 2023, so that the appellant had sufficient time to respond to the response to the appeal before the summons. Nor were any exceptional circumstances claimed under Article 13(2) RPBA 2020." 
EPO 
The link to the decision is provided after the jump, as well as (an extract of) the decision text.


22 March 2024

T 1660/22 - Disclosed disclaimer, and lacking rejoinder

Key points

  • The OD found the claims as granted to be allowable.  The opponent appeals. The Board arrives at AR-5, filed before the OD and resubmitted by the patentee/respondent in their reply to the appeal.
  • AR-5 specifies the absence of a catalyst in the claimed process.
  • " The subject-matter of claim 1 contains a (disclosed) disclaimer. The question to be assessed is whether the remaining claimed subject-matter was directly and unambiguously disclosed in the application as filed (G 2/10 ...)" 
  • " The original disclosure also contained the method for producing HFSI without a catalyst, as is apparent from the published original application (A1). A1, paragraphs [0024], [0025], [0028] and [0032] disclose that a catalyst is optional. Paragraph [0031] even discloses that the reaction does not require a catalyst to give acceptable results. Example 2, carried out without a catalyst and showing a yield of 98%, supports this statement. Therefore, the remaining subject-matter, i.e. the method for producing HFSI at a high yield by reacting HXSI with HF under reflux conditions to remove HX, in the absence of a catalyst, is directly and unambiguously derivable from the application as originally filed." 
  • Turning to the admissibility of the inventive step objections, " In the statement of grounds of appeal, the appellant merely attacked the dependent claims of the main request. The disclaimer contained in claim 1 of auxiliary request 5 was, however, not contained therein. Moreover, the appellant did not submit arguments against the auxiliary requests as filed during the opposition proceedings and as resubmitted with the reply to the appeal. The appellant's submissions in particular did not address an embodiment without a catalyst. Only during the oral proceedings before the board did the appellant argue against the inventive step of claim 1 of auxiliary request 5." 
  • The Board's reasoning is not unambiguous but is consistent with the view that the opponent was not required to comment on AR-5 in the statement of grounds (as the OD did not reach AR-5 in their decision) but should have filed a rejoinder when AR-5 was resubmitted in appeal.

EPO 
The link to the decision is provided after the jump, as well as (an extract of) the decision text.

20 March 2024

T 1416/21 - Reworking the example from 1956

Key points

  • The claim at issue is a product claim directed to " "Crystalline 2'-O-fucosyllactose polymorph II" (having certain XRD peaks) . The compound 2'-O-fucosyllactose  "was first discovered in the 1950s in human milk" (wiki)
  • D1 is Kuhn, R. et al., Chem. Ber. 1956, page 2513
  • The opponent/respondent: "  Method 2 of D1 represented an enabling disclosure. Experiment 1 of D21 was a proper repeat of method 2 of D1, i.e. a repeat which the skilled person would have carried out having their common general knowledge in mind. The product of experiment 1 of D21 showed the XRPD peaks provided for in claim 1 of the main request and auxiliary requests 1 to 9. "
  • " The board agrees with the respondent that experiment 1 of D21 is a proper repeat of method 2 of D1, i.e. a repeat which the skilled person would have carried out having their common general knowledge in mind. In particular, in both method 2 of D1 and experiment 1 of D21, amorphous 2'-FL is dissolved in a certain volume of aqueous methanol and the solution is diluted with the same volume of n-butanol. Afterwards, a few drops of n-hexanol are added and crystallisation is carried out at 4 °C."
  • Claim 1 is found to be not novel.

EPO 
The link to the decision is provided after the jump, as well as (an extract of) the decision text.



2. The respondent put forward a novelty objection to the subject-matter of claim 1 based on D1.

3. D1 addresses the problem of providing crystalline 2'-FL. It states (lines 1 to 6) that purification of 2'-FL by repeated chromatography or via its tosylhydrazone does not immediately yield crystalline 2'-FL. Rather, a syrup or, after treatment with alcohol, an amorphous white powder is obtained first.

3.1 According to D1 (lines 6 to 10), crystalline 2'-FL can be obtained from the above-mentioned syrupy 2'-FL as follows (denoted as "method 1" by the parties):

"Nach längerem Aufbewahren von 2.1 g eines mit Wasser abgedampften Sirups bei ~20° schieden sich am oberen Teil der Kolbenwand einige weiße Kriställchen ab, mit deren Hilfe sich der gesamte Sirup über Nacht in ein lockeres Kristallpulver verwandeln ließ."

[translation by the board: After storing 2.1 g of a water-evaporated syrup for an extended period of time at approximately 20°, some white crystals separated at the upper part of the wall of the flask, with the help of which the entire syrup could be transformed into a loose crystalline powder overnight.]

3.2 D1 further discloses (lines 10 to 17) that, starting from amorphous 2'-FL, crystalline 2'-FL can be obtained as follows (denoted as "method 2" by the parties):

"Ein anderer Ansatz, in dem nach mehrwöchigem Aufbewahren bei +4° spontan Kristallisation eintrat, war durch Lösen von amorphem Trisaccharid in wasserhaltigem Methanol und Zugabe des gleichen Volumens n-Butanol sowie einiger Tropfen n-Hexylalkohol bereitet."

[translation by the board: Another approach, in which spontaneous crystallisation occurred after several weeks of storage at +4°, was conducted by dissolving amorphous trisaccharide in aqueous methanol and adding an equal volume of n-butanol along with a few drops of n-hexyl alcohol.]

3.3 Finally, D1 states (lines 19 to 22) that crystalline 2'-FL can also be obtained by using the crystalline products of the above two methods as seed crystals in the following method (denoted as "method 3" by the parties):

"Besitzt man Impfkristalle, so läßt sich die Fucosido-lactose (l g) durch Lösen in heißem 75-proz. Methanol (20 ccm) und allmähliche Zugabe von absol. Äthanol (60-80 ccm) leicht in schönen dreieckigen Plättchen (Abbild.) vom Schmp. 230-231° (Zers.) erhalten."

[translation by the board: If seed crystals are available, fucosido-lactose (1 g) can be easily obtained as nice triangular plates (see image) with a melting point of 230-231° (decomposition) by dissolving the crystals in hot 75% methanol (20 ccm) and gradually adding absolute ethanol (60-80 ccm).]

3.4 The above understanding of D1, i.e. that method 3 uses the crystals of method 1 or 2 as seeds, is consistent with the summary of D1 in paragraph [0003] of the patent and was also common ground between the parties at the oral proceedings before the board.

3.5 With respect to the crystalline 2'-FL obtained, D1 also states (lines 22 to 23) that it is non-hygroscopic.

This property of the crystalline 2'-FL is mentioned in D1 only after the description of method 3. Contrary to the appellant's view, however, this does not mean that this property characterises only the crystals resulting directly from method 3. In the present case, the crystals obtained by method 1 or 2 are used as seed crystals in method 3 (see above). This means that the crystals of method 3 are obtained from these seed crystals by further growth. Therefore, the board concurs with the respondent that it is not apparent why the crystals from method 3 should have different properties than those resulting from method 1 or 2. In summary, D1 can only be understood as meaning that the above property (non-hygroscopic) characterises the crystals of 2'-FL no matter which of the three disclosed methods is used.

4. D1 does not disclose XRPD reflections of the crystals from any method or the degree of their purity in w/w%. However, this does not mean that its disclosure cannot be novelty-destroying. To the extent that the teaching of D1 is sufficient for the skilled person, in light of their common general knowledge, to obtain the product of claim 1 (in other words: if D1 provides an enabling disclosure for the product of claim 1), D1 would be novelty-destroying to claim 1.

4.1 In this context, experiment 1 of D21 (page 2/20) is relevant. It reads as follows (text in square brackets added by the board):

"In order to repeat the Method 2 in Literature 1 [D1] the following experiment was carried out: 2.527 g of amorphous 2-FL [2'-FL] was dissolved in 100 ml of aqueous methanol (99 ml of anhydrous methanol + 1 ml of water), and the white solids were gradually dissolved under continuous stirring, the liquid became a white turbid liquid, and then 100 ml of n-butanol was added, and more white solids were precipitated. The solution was filtered to obtain a colorless transparent solution, and then 400 myl of n-hexanol was added to the filtrate, and shaken. The solution was transferred to a 250 ml conical flask, sealed with a parafilm perforated with several small holes, and stored at 4 °C for 2 weeks. The crystalline product was filtered, washed with methanol, and dried in vacuo to obtain 0.314 g of white crystals."

4.2 The board agrees with the respondent that experiment 1 of D21 is a proper repeat of method 2 of D1, i.e. a repeat which the skilled person would have carried out having their common general knowledge in mind. In particular, in both method 2 of D1 and experiment 1 of D21, amorphous 2'-FL is dissolved in a certain volume of aqueous methanol and the solution is diluted with the same volume of n-butanol. Afterwards, a few drops of n-hexanol are added and crystallisation is carried out at 4 °C.

4.3 As is evident from figure 4 and table 1 of D21 (pages 10/20 and 11/20), the crystals obtained from this repeat show the XRPD reflections recited in claim 1. This was also never disputed by the appellant.

4.4 Furthermore, as already set out above, D1 uses a 2'-FL as the starting material for its crystallisations which had previously been purified by repeated chromatography or via its tosylhydrazone. D1 (last sentence) also states that no other sugars could be detected in the mother liquors by paper chromatography after crystallisation.

Against this background, at least in the absence of any evidence to the contrary, which the appellant did not provide, the board is convinced that the crystalline 2'-FL obtained according to the disclosure of D1 and in particular method 2 does not contain any impurities.

5. The appellant submitted that D1 did not disclose method 2 in an enabling manner. In this respect, it referred to paragraph [0016] of the patent, stating that the inventors of the patent had never been able to reproduce the methods described in D1. Decisions T 325/16 and T 605/02 were relevant in this context. In particular, the appellant argued that several pieces of information were lacking in D1 so that especially method 2 might not be reproduced. Experiment 1 of D21 filled in these gaps in the disclosure of method 2 of D1. Contrary to D21, D1 did not specify the amounts of solvents or 2'-FL used nor did it exactly specify the number of drops of n-hexanol added or the storage time; moreover, D21 disclosed that the liquid became a white turbid liquid, an item of information that was not mentioned in D1. Therefore, several additional assumptions had been made in D21 that could not be derived from D1 nor from the skilled person's common general knowledge. The appellant also pointed to the fact that, according to D21, the crystalline product was obtained after only two weeks, whereas D1 disclosed the obtention of the crystals after "several weeks".

Furthermore, the appellant referred to D6 and submitted that it was evident from figure 1 of D6 (page 946) that several parameters such as e.g. choice of solvent, temperature, concentration, agitation and pH all had an effect on the type of polymorphic form that was obtained from a solution during crystallisation. Therefore, it was entirely conceivable that the polymorph as defined in claim 1 had been obtained in D21 by selecting appropriate operating conditions that were not mentioned in D1 but that only slight changes in the crystallisation conditions of experiment 1 of D21 would have resulted in a different polymorph.

Hence, the appellant argued that D21 was not a proper repeat of method 2 of D1 and therefore it could not be concluded that the 2'-FL polymorph of claim 1 was necessarily obtained when following the teaching of method 2 of D1.

6. The board is not convinced by these arguments for the following reasons.

6.1 It is clear that method 2 of D1 is not described to the very last detail. However, this does not allow the conclusion that the method is necessarily not disclosed in an enabling manner. In the present case, the board is convinced that the skilled person, having their common general knowledge in mind, would have known how to put method 2 of D1 into practice. The appellant's arguments are not suitable for casting doubt on this for the following reasons.

6.1.1 First of all, both the storage time at 4 °C (2 weeks) and the amount of n-hexanol (400 myL, i.e. about 8 drops) reported in D21 are fully in line with the disclosure of method 2 in D1 ("nach mehrwöchigem Aufbewahren" [translation by the board: after several weeks of storage], "sowie einiger Tropfen n-Hexylalkohol" [translation by the board: along with a few drops of n-hexyl alcohol]). In the absence of evidence to the contrary, which the appellant did not put forward, the board sees no reason to doubt that the skilled person would very well have chosen the storage time and number of drops of n-hexanol as stated in experiment 1 of D21.

6.1.2 Secondly, it is true that the amounts of solvents and 2'-FL used in experiment 1 of D21 are not disclosed in D1. However, the skilled person is well aware that any compound which is to be crystallised from a solvent or a solvent system has a certain solubility at a certain temperature in said solvent (system). Consequently, depending on the amount of compound to be crystallised, the skilled person would have used only those amounts of solvent(s) which result in a concentration of the compound to be crystallised which is above the solubility limit at the crystallisation temperature, because no crystallisation at all could otherwise have been achieved. In simpler terms, as argued by the respondent, the skilled person would have known how much solvent to use depending on the amount of 2'-FL to be crystallised. This is what has been done in experiment 1 of D21.

6.1.3 Thirdly, D21 also states that "the liquid became a white turbid liquid" upon dissolution of the amorphous 2'-FL in aqueous methanol. The appellant pointed to the fact that this observation is not described in method 2 of D1. This argument implies that according to the appellant, the solution in D1 must have been clear upon dissolution of the amorphous 2'-FL in aqueous methanol. However, in the absence of evidence to the contrary, which the appellant did not provide, the board sees no reason for this assumption. In fact, according to experiment 1 of D21 (loc. cit.), a clear solution is obtained by filtration. Thus, the board is satisfied that this is exactly what the skilled person would have done by following method 2 of D1 if they had wanted to prepare a solution from which a compound was to be crystallised.

6.2 Therefore, the appellant's arguments cannot change the conclusion above that method 2 of D1 is disclosed in an enabling manner and that experiment 1 of D21 is a proper repeat of method 2 of D1, i.e. a repeat which the skilled person would have carried out having their common general knowledge in mind.

6.3 In view of the above, the mere assertion in the patent that the appellant tried in vain to repeat the methods of D1 is not convincing. In fact, as submitted by the respondent, the appellant has not provided any details concerning the operating conditions that might have been used in these attempts to reproduce the methods of D1 and which would not have allowed crystallised 2'-FL to be obtained.

6.4 It may be that, as argued by the appellant with reference to D6, a slight modification of the crystallisation conditions of experiment 1 of D21 could have in principle resulted in a different polymorph. However, the allegation that such is exactly the case here has never been proven by the appellant and, thus, amounts to mere speculation.

6.5 The appellant also referred to decisions T 325/16 and T 605/02, arguing that a polymorph disclosed in the prior art in a non-enabling manner could not be novelty-destroying. The board had already pointed out the lack of relevance of these decisions in its communication pursuant to Article 15(1) RPBA 2020 (see point 3.4.8). This is because the underlying facts were different from the facts at hand. Moreover, as set out above, the board is convinced that the polymorph defined in claim 1 is disclosed in D1 in an enabling manner. At the oral proceedings before the board, the appellant no longer relied on these decisions in its argumentation. Hence, the board sees no reason to comment on them further.

7. Therefore, the board concludes that method 2 of D1 is disclosed in an enabling manner and that it results in the claimed 2'-FL polymorph without any impurities. Hence, the subject-matter of claim 1 of auxiliary request 2 is not novel over D1. Auxiliary request 2 is not allowable.

Main request and auxiliary request 1 - Claim 1 - Novelty (Article 54 EPC)

8. Claim 1 of auxiliary request 1 differs from claim 1 of auxiliary request 2 only in that it allows for a higher degree of impurity ("less than 10 w/w% of impurity" in claim 1 of auxiliary request 1 vs. "less than 5 w/w% of impurity" in claim 1 of auxiliary request 2). Claim 1 of the main request (claim 1 as granted) does not set any limit to the amount of impurity.

Therefore, the subject-matter of claim 1 of auxiliary request 2 is fully encompassed by the subject-matter of claim 1 of the main request and auxiliary request 1. The above reasoning of lack of novelty for the subject-matter of claim 1 of auxiliary request 2 therefore also applies to the subject-matter of claim 1 of the main request and auxiliary request 1.

It follows that the subject-matter of claim 1 of these requests is not novel over D1 and therefore the main request and auxiliary request 1 are not allowable.


19 March 2024

T 0223/23 - Product claims based on inventive preparation method

Key points

  • Application filed in 2021, appeal decision on the grant on 08.01.2024. Things could be improving.
  • "Claim 1 of the main request related to:

    "A trace element solution, which comprises at least the following metals: (a) zinc in a concentration of at least 60mg/ml; (b) manganese in a concentration of at least 10mg/ml; (c) selenium in a concentration of at least 5mg/ml; and (d) copper in a concentration of at least 15mg/ml; and which comprises a concentration of the metals of at least 90 mg/ml."

  • "The application relates to a solution containing trace elements useful for administration to mineral deficient animals such as livestock. It seeks to address the problem of low concentrations of the minerals in injectable solutions, leading to the injection of large quantities, which causes tissue damage and abscesses at the site of injection. The invention aims at providing solutions with suitable composition with high enough concentrations and sufficient ratios and sufficient concentrations of the various metals"

  • The application discloses a rather specific method of making the solution, by adding various salts in a particular order to water, and also adding EDTA in a specific step.

  • The closest prior art D1 (see example 6) shows a trace element solution

  • The desirability of a higher metal concentration and the ensuing advantages upon injection are known from D1 (see page 1) and are as such obvious. However, it is apparent that, at the date of filing of the application, there was no obvious way to produce a solution as claimed with a metal concentration of at least 90 mg/ml.

  • As a quick test, what is the decision you need in such a case?

  • "the increased concentration of trace elements in solution is obtained [in the application] in particular by a specific order of adding EDTA. The prior art does not allow the skilled person to anticipate that this particular order of addition would lead to the claimed higher concentrations, nor does it appear to suggest any obvious way leading to such high concentrations."

  • "According to established case law, a product which can be envisaged as such with all characteristics determining its identity including its properties in use, i.e. an otherwise obvious entity, might nevertheless become non-obvious and claimable as such, if there is no known way or applicable (analogous) method in the art for making it and the claimed methods for its preparation are therefore the first to achieve this and do so in an inventive manner "

  • See T 0595/90 Kawasaki Steel


  • These criteria are met.
  • "The examining division however found that the criteria of Article 84 EPC were not met"
  • "The examining division argued that it was the process of manufacturing, and in particular the specific order of adding EDTA, that provided the trace element in solution.

    As a preliminary remark, claim 1 relates to a product per se. Additionally defining this product in terms of the process used for its preparation, i.e. by a product-by-process feature, could only further characterise the composition insofar as this process gives rise to a distinct and identifiable characteristic of the product. In this sense, the steps of the process cannot themselves be regarded as essential features of the product: at most the technical features imparted by this process to the resulting product could represent such essential features."

  • "The Board understands the examining division's conclusions to be motivated by the finding that the preparation of a trace elements solution with the claimed high concentration could not be achieved in the prior art and was part of the problem to be solved mentioned in the application, and that the process disclosed in the application was the first process to allow such a preparation (as explained above, see 3.2). However this situation does not justify that each and every feature imparted by the process shown in the example to the resulting composition be seen as an essential feature. As explained in T 242/92, the mere fact that only one way of carrying out the invention is indicated does not in itself offer grounds for considering that the application is not entitled to broader claims (see point 3 of the reasons). A lack of support would only arise if there are well-founded reasons for believing that the skilled person would be unable to extend the particular teaching of the description to the whole of the field claimed by using routine methods. The Board sees no such reasons in the present case. In particular, the absence of reference in claim 1 to the EDTA used in the example does not lead to a lack of support, considering that the description mentions EDDS as an alternative, and considering the absence of an indication that the skilled person could not use other chelants."

  • "For the reasons given above (see 4.1.3), even if, according to the description, the invention aims at providing a highly concentrated trace element solution, and provides for the first time a process allowing the preparation of such a highly concentrated solution, this does not mean that the claims should be limited to that particular process or to a solution defined in terms of that particular process for them to comply with Article 84 EPC."


EPO 
The link to the decision is provided after the jump, as well as (an extract of) the decision text.


18 March 2024

T 1845/21 - CPA is a set of features disclosed in combination; multiple CPA

Key points

  • "The specific starting point for assessing inventive step is normally a set of features disclosed in combination in a document, e.g. an embodiment or example."
  • " For assessing inventive step it is necessary to establish the distinguishing features over that specific starting point and assess whether it was obvious to arrive at the claimed subject-matter when starting from that specific point (T 1287/14, Reasons 5.2.1)."
  • Disclosure, however, can be implicit.
  • D3, Example 3 is the closest prior art.
  • "The combination of all these features (toddler milk of example 3, which in view of the above [considerations] implicitly comprises LC-PUFA, and [implicitly ] for use in preventing infections) is considered the closest prior art for examining the inventive step of claim 1."

  • "Prior to identifying the closest prior art in its statement setting out the grounds of appeal, appellant 1 extensively outlined what it deemed to be common general knowledge. While a brief introduction of the common general knowledge prior to identifying the closest prior art may occasionally be helpful, an extensive discussion on this matter bears the risk of adding hindsight to a party's argument. Such a discussion might undo the desired effect of the problem-solution approach, namely to assess inventive step as objectively as possible, although the assessment is unavoidably made in full knowledge of the invention. Nevertheless, the board understands appellant 1's submissions ..."
Multiple starting points

  • D45a was also proposed as the closest prior art.
  • "A discussion of the entire problem-solution approach starting from a document as a further starting point may be dispensed with if, following a discussion on whether the document is suitable as the closest prior art, the board concludes that this is not the case (see T 1230/15, point 2.4)."
  • "The understanding that a party is not generally entitled to orally present an entire problem-solution approach at oral proceedings is also conveyed in R 5/13 (Reasons, 14 and 15). Such an approach ultimately serves procedural economy."
  • " D45a relates to an announced study on the effect of growing-up milk on the occurrence of infections in toddlers. The hypothesis underpinning the study is the expectation that drinking growing-up milk with added "prebiotics and LCPUFA" results in a lower occurrence of infections."
  • "without the benefit of hindsight, D45a would have provided the skilled person with next to no useful information. ... It is worth noting that in the current case, hindsight is particularly difficult to put aside, the reason being that the results of the study are described in D35, published after the filing date of the patent. D35 is also the document that appellant 1 discussed in detail throughout the appeal proceedings, e.g. in the context of sufficiency of disclosure. Moreover, the results of the study are summarised in example 1 of the patent."
  • " To conclude, the disclosure of D45a is vague and blurred, so this document is not considered a more promising springboard than D3 for assessing the inventive step of claim 1." 
  • Inventive step over D45a is no further discussed.
EPO 
The link to the decision is provided after the jump, as well as (an extract of) the decision text.

15 March 2024

T 0298/20 - Specific for sufficiency, specific for inventive step

Key points

  • The claim is a second medical use claim.
  • "D6 (points 1 and 3) is a draft of the guidelines proposed by a group of experts consulted by the FAO and the WHO for evaluating the use of therapeutic probiotics in food. In the first paragraph of point 3.1, D6 underlines the importance of identifying probiotic strains because, according to the available evidence, the effect of probiotics on health is strain specific. "
  • For sufficiency: "It follows from D6 and D7 that on the filing date it was generally accepted that the health benefit provided by a probiotic was strain specific. Only in exceptional cases had it been observed that the effect of a strain was common to the whole species. There is no experimental evidence on file that the health benefits obtained by the administration of L. acidophilus NCFM and B. lactis Bi-07 [as used in the examples] can also be obtained with other strains of the species L. acidophilus and B. lactis [as encompassed by the claim]."
  • " Therefore, the Board has serious doubts that, on the filing date, the skilled person could carry out the invention of claim 1 without undue burden. As a consequence, the ground for opposition of Article 100(b) EPC precludes the maintenance of the patent as granted."
  • Turning to inventive step of AR-3 where the claim is limited to the specific strains that were tested, " the subject-matter of claim 1 differed from D2 at least in the combination of bacterial strains that were administered to children. In claim 1, it was a combination of L. acidophilus NCFM and B. lactis Bi-07, while in D2 it was a combination of L. rhamnosus GG or L. delbrueckii bulgaricus and B. lactis Bb-12."
  • "the results of the clinical study in the patent (see Tables 2 and 3 and paragraph [0097]) demonstrate that the administration of the bacterial strains in claim 1 prevents or reduces flu-like symptoms in children affected by respiratory tract infections. Therefore, the objective technical problems is, as proposed by the patent proprietor, the provision of a probiotic composition for reducing or preventing flu-like symptoms in a child affected by a respiratory tract infection."
  • 'As concluded for sufficiency of disclosure of the main request (point 5.2 above), on the priority date, it was generally accepted by the scientific community that the beneficial effects of probiotics on human health were strain dependent. The fact that L. acidophilus NCFM and B. lactis Bi-07 were known probiotics did not provide the skilled person with a reasonable expectation that they would have an effect on the flu-like symptoms of children affected by respiratory tract infections. Neither of the two strains had been disclosed to have such an effect."
EPO 
The link to the decision is provided after the jump.

14 March 2024

T 1628/21 - Claim interpretation

Key points

  • "The question ... arises as to the extent to which the description and drawings can be used to interpret the claims. Neither Article 69 nor its Protocol explicitly addresses this topic. Nevertheless, the principle of primacy of the claims seems to exclude the use of the description and drawings for limiting the claims if an interpretation of the claim in the light of common general knowledge already leads to a technically meaningful result. Similarly, the principle, established by case law, according to which "limiting features which are only present in the description and not in the claim cannot be read into a patent claim" is also fully compatible with Article 69 EPC and Article 1 of the Protocol (cf. T 1473/19, Reasons 3.16.1)."
  • "the description itself is of course not without any function when considering the patent. When referring to the description, the reader is informed inter alia of the technology involved and the background used by the skilled person in understanding the patent, as well as prescribing particular embodiments of interest. The claims are thus not to be seen in a pure vacuum, but, having regard to the description, in the context of the area of technology addressed by the patent. Nevertheless the description should not normally be used to derive possible limitations to claim scope; it is the purpose of the claims and indeed the wording of the claims themselves which define a certain scope and thus the protection sought. It may be that the reader is presented with specific definitions in the description in cases where terminology in the claims is e.g. unusual or where special meanings are attributed. However such definitions, if relevant for validity, should normally be included in the claims, for example where the normal meaning of a term in the claim is no longer intended."
  • "How such a definition might be presented in the description and whether it might have a special significance for the scope of the claim in a particular case, is however of no relevance in the case at hand since there is no such definition of "engaged with" in the description. Instead, in the paragraphs mentioned by the respondent, the references are far more general."
  • "as discussed during oral proceedings before the Board, none of the passages of the description forms a definition of what "engaged with" must be understood to mean. Instead, the respondent [proprietor] attempts to rely on these "disclaimer-like" statements in the description to try to limit the claims, without however introducing any restricting definition or disclaimer into the claims themselves."
  • Claim 1 at issue is held to be not novel.
  • The case is remitted for auxiliary request 1. 
  • "Although the Board notes that the patent expires in 2028 at the latest, this fact is not of itself a sufficient reason to override the parties' requests in the present case, noting that possibilities for requesting accelerated prosecution exist. Issues concerning the format of the claim, currently in an (incorrect) two-part form, may also be addressed by the parties."
EPO 
The link to the decision is provided after the jump, as well as (an extract of) the decision text.


13 March 2024

T 0433/21 - (II) Habermas and the Enlarged Board

Key points

  •  The Board, in this case, decided to refer no questions to the Enlarged Board.
  • "The Board agrees [with the appellant] that the issue is relevant to the specific case at hand, but not to the European patent system in general."
  • "As an additional consideration, the Board notes that the above criteria for a referral as set out in G 1/12 were written from the perspective of the body to whom the case was referred (the Enlarged Board of Appeal) and concerned the question of admissibility of the referral. From the point of view of the referring Board, admissibility of a referral is of course a necessary prerequisite. However, this does not mean that every referral that would be admissible must necessarily be made. Rather, the decision to refer is a discretionary one (Bühler, in: Singer/Stauder, Europäisches Patentübereinkommen, 8th ed. 2019, Art. 112 note 16). However, where a Board wants to deviate from an earlier decision of the Enlarged Board, it should refer the question (stipulated in Art. 21 Rules of Procedure of the Boards of Appeal for reasons of comity)."

  • "The fact that this is not a Common Law jurisdiction allows for contradictory decisions to coexist. The disadvantage thereof may - to a certain extent and for a limited time - be offset by the possibility of different Boards engaging in a non-coercive discourse with each other. A non-coercive discourse ("herrschaftsfreier Diskurs") according to Wolfgang Habermas (elaborated in "Theorie des kommunikativen Handelns" 1981) has as its object a decision through the persuasive force of the best argument. It requires equal partners in a communication, an equal opportunity to be heard and a symmetrical situation, all of which is given when different Boards, which are not in a hierarchy amongst each other and are equally competent to interpret the EPC, decide on the same question of law and are forced to come up with better arguments when contradicting each other. Ideally, a sequence of such decisions can then lead to a common understanding as to the best argument and the best answer to a given legal problem. "
  • "A Board may therefore refrain from making a referral in the belief that its own decision, as part of a non-coercive discourse, will lead to a commonly accepted answer to a certain legal problem. Particularly in cases where a problem has only recently been identified, a non-coercive discourse may be helpful in arriving at a commonly accepted answer or in providing an argumentative basis for a future referral."

  • For the substance of the case, see this earlier post
  • At the time of writing, the Boards seem to be engaged in a herrschaftsfreier Diskurs on claim interpretation. 

  • A related point is the Hart-Dworkian debate, in particular, whether it is correct that "The set of (...) valid legal rules is exhaustive of ‘the law,’ so that if someone’s case is not clearly covered by such a rule (because there is none that seem appropriate, or those that seem appropriate are vague, or for some other reason) then that case cannot be decided by ‘applying the law.’ It must be decided by some official, like a judge, ‘exercising his discretion.’"? (Dworkin, stating what he considers to be Hart's position, in “The Model of Rules I,” 17 as cited by Shapiro in The Hart-Dworkin Debate: A Short Guide for the Perplexed). In other words, does the Enlarged Board tell us what the law is (and always was) or do they create it on the fly? Especially in the latter case, a preceding sequence of decisions of the Technical Boards of Appeal, prior to the referral, can be helpful to clarify the issue and to better develop respective views, which may help the Enlarged Board of Appeal to settle the debate. 
EPO 
The link to the decision and (an extract of) the decision text are provided after the jump.


12 March 2024

R 0007/21 - Review of decisions to hold inadmissible

Key points

  • "The exercise of discretion [by the Board of Appeal] is only subject to review if arbitrary or manifestly illegal, ("... illégalité manifestes ...", see R 10/11 para 5.2), thereby involving a fundamental violation of the right to be heard (R 9/11)."
  • This implies that the Enlarged Board will only allow a petition for review based on a violation of the right to be heard by a decision of a Board to hold a submission inadmissible if the exercise of discretion by the Board is arbitrary or manifestly illegal (but then will do so) (and provided that the Board indeed had a discretionary power to hold the submission inadmissible). 
  • Decision  Board of Appeal: 19.03.2021 (written decision). The decision of the Enlarged Board of Appeal in the three-member panel was issued on 05.03.2024 (written decision). 
  • Decision OD: 2018. Grant: 2014. Filed as PCT application: 2006. 
EPO 
The link to the decision is provided after the jump, as well as (an extract of) the decision text.

11 March 2024

T 0712/21 - The inherent limitations of technical language

Key points

  • Claim 1 of this examination appeal is directed to "1. A process for producing biofuel or biofuel components, comprising:  .... wherein the feed material is contacted, in at least one catalyst bed..., with a combination of hydrodeoxygenating (HDO) and hydrodewaxing (HDW) catalysts"
  • " The examining division argued that Article 84 EPC was not satisfied because the invention was defined in terms of a result to be achieved, namely hydrodeoxygenation (hereinafter "HDO") and hydrodewaxing (hereinafter "HDW") steps, for which no indication was given as to the extension of the desired reactions. According to the examining division, in order to meet the requirements of Article 84 EPC, the claim should define all the essential features for obtaining these results, i.e. for carrying out the HDO and the HDW steps."
  • "2.4.2 In the Board's view the features HDO and HDW also meet the requirement of clarity under Article 84 EPC, and in this respect, it is important to emphasise the differences between lack of clarity and breadth of the claims. A feature may be considered to be unclear if its boundaries are diffuse, leaving the reader in doubt as to whether certain embodiments fall within or outside the scope of protection. This generally occurs when the feature is defined in confusing or incomplete terms (e.g. an ill-defined parameter) and/or when it is inherently unsuited for providing a well-defined scope (e.g. relative terms)."
  • "On the contrary, features with generally accepted meanings shouldn't be considered unclear just because they are broadly defined. The confusion between breadth and lack of clarity arguably results from the minor ambiguities found at the edge of the scope defined by broad technical terms. For instance, one could question whether the term "furniture" encompasses household accessories or decorative elements. Similar ambiguities can arise with simple terms like "window," which might be difficult to distinguish from certain elements like patio doors with a framed glass."
  • "In the present case, it is undisputed that the terms "HDO" and "HDW" have a generally accepted meaning in the underlying technical field. Therefore, although it may be argued that the scope of these features could overlap with that of similar processes (e.g. does a hydrotreating process fall within or outside the scope of HDO?, or does a hydroisomerisation step fall within or outside the scope of HDW?), such challenges arise not due to a faulty or incomplete definition, but because language can't comprehensively capture every detail of real-life objects or processes, an issue which becomes more pronounced when features are broadly defined."
  • "The Board therefore considers that the basic question to be asked is whether the vagueness of the scope of protection is the result of an incorrect, incomplete or relative feature, or whether it is simply the result of the inherent ambiguity of technical terms. In the present case, the Board concludes that the features HDO and HDW would be clear to a person skilled in the art and that any ambiguity in distinguishing them from other similar processes should be attributed to the inherent limitations of technical language."
EPO 
The link to the decision is provided after the jump, as well as (an extract of) the decision text.

8 March 2024

T 0053/22 - Bonus effects

Key points

  • "The invention relates to a manufacturing method of a turbine wastegate." "A turbine wastegate is a valve []. It includes a wastegate seat, a plug, an arm connected to the plug, a shaft, [and] a control arm at the opposite end of the shaft."
  • "The invention aims at improving fit of the plug to the arm, shaft and wastegate seat for reducing leakage. With this aim the assembly process includes welding of the arm to the plug in a closed position against the seat in the turbine housing. Such a method reduces clearances and customizes fit of the plug".
  • The method specifies a step of "applying a force to a control arm operatively coupled to the shaft"; this force is used to maintain the arm and the plug in a closed position against the seat.
  • The opponent: "D2 is silent about where to apply the force to the actuating element [(which is the subunit formed by the shaft and the arm in the sense of the contested patent) ] while performing the welding step between actuating element and plug in the manufacturing method described there. Applying it to a control arm operatively coupled to the actuating element's shaft is an obvious choice for the skilled person when tasked with carrying out in practice the method taught by E2."
  • The Board: "The objective technical problem [over D2] must be formulated based on effects that can be associated with the differentiating feature of applying force to an operatively connected control arm"
  • "In the Board's view the primary, main effect associated with specifying that force is applied via the control arm is that it allows D2's teaching to be put into practice. As noted D2 only states that force is applied by means of the actuating element 5 but gives no further detail. Therefore, if the skilled person wants to carry out D2's teachings, it must first identify a suitable way of applying force by means of the actuating member to produce the required contact pressure for welding. In the Board's view this is an objective and realistic reflection of what a skilled person, in this case an engineer designing turbochargers, would do and the considerations they would have when confronted with the teaching of D2. It thus seems reasonable to formulate the objective technical problem starting from D2 accordingly, and as broadly as possible, as how to practically implement the invention taught by D2. "
  • "As variously stated in case law, once a realistic problem has been defined and once it has been established that a particular solution to such a problem is obvious, that solution cannot be said to involve an inventive step, and this assessment is not altered by the fact that the claimed invention inherently also solves further technical problems"
  • "The respondent proprietor argued that using the control lever reduces the introduction of undesirable misalignment in the control linkage" "If not already the primary effect on which the objective technical problem should be based, it was more than just a "bonus effect". For it to be a "bonus effect", the respondent proprietor argues, citing CLBA, 10th edition, 2022, I.D.10.8 and case law mentioned therein, the skilled person must be in a "one-way street" situation with no other alternative courses of action." (according to the proprietor).
  • " The Board has already indicated above why it considers any further effect, and thus also the (further) reduction of misalignment, to be only secondary or supplementary to the primary effect of realizing D2's teaching. Because, as also explained above, there are only very few realistic options available to the skilled person when carrying out D2's teaching to press the plug into its seat by means of the actuator, and these are all known and thus obvious to them, the presence of a further effect (whether surprising or not) cannot change the fact that each of these very few options is obvious. The situation may be different if there is a "multiplicity", as in "a large number", of options as in the case law cited, e.g. T0192/82. There, and in other cited decisions, it was held that if a selection of one amongst many options could be associated with a (derivable and plausible) "surprising effect" then that selection was non-obvious by virtue of that surprising effect."
  • "Nor is this case similar to T0848/94, where the Board held an effect arising from a combination of measures to be a synergistic effect and not a bonus effect, because that combination of measures, that might each be prima facie obvious, was not a "one-way street", that is something the skilled person would inevitably do. In this case it has not been argued that the reduced misalignment would be a synergistic effect arising from a combination of measures."
  • "Further cited T0936/96 in section 2.6 underscores the general approach to bonus effects mentioned above without reference to a "one way street". Indeed, it is clear from section 2.4, last paragraph, that there were several choices available to the skilled person, but that nonetheless the alleged effect was seen to be a bonus effect that could not render an obvious combination inventive"
  • See also T 1356/21.

EPO 
The link to the decision is provided after the jump, as well as (an extract of) the decision text.


7 March 2024

R 0006/22 - How to object under Rule 106

Key points

  • "The reasoned petition was filed on 18 February 2022" 
  • The written decision was issued on 28 February 2024, i.e. after more than two years, by a panel of the Enlarged Board consisting of three members. I will leave the issue of the length of the procedure aside for now, but not because it is an unimportant issue.
  •  Rule 106 provides that a petition for review "is only admissible where an objection in respect of the procedural defect was raised during the appeal proceedings and dismissed by the Board of Appeal, except where such objection could not be raised during the appeal proceedings"
  • "Oral proceedings before the Board were held on 15 November 2021. The Board's contested decision was announced at the end. The minutes were posted on 19 November 2021 and do not contain any detail of the arguments relied on for the various discussed issues. For the purposes of the petition, the discussion of the main request and auxiliary request is relevant."
    • Note, the parties are effectively prevented from keeping a proper record of the oral proceedings by the prohibition of sound recording. 
  • "From the minutes it transpires that the issues of added subject-matter, novelty and inventive step for the main request and of the admittance of the auxiliary request were discussed without interruption. After the Board's deliberation on these issues, the Chair announced that the main request was novel but did not involve an inventive step, and that the Board did not admit the auxiliary request into the proceedings. This was followed by a discussion on apportionment of costs. "
  • "The petition is essentially based on the two grounds that (1) the non-admittance of the auxiliary request constituted a violation of the right to be heard since the auxiliary request had been submitted in response to a new argument raised by the Board"
  • The EBA: 'From the file it appeared that an objection under Rule 106 EPC had not been made when the Board announced that it would not be admitting the auxiliary request into the proceedings. Mere observations on the right to be heard did not qualify as an objection under Rule 106 EPC unless they were immediately and doubtlessly recognisable as such. "
  • "An objection under Rule 106 EPC must be expressed by a party in such a form that a board is able to recognise immediately and without doubt that an objection under Rule 106 EPC is intended. An objection under Rule 106 EPC is in addition to and distinct from other statements, such as arguing or even protesting against the conduct of the proceedings or against an individual procedural finding."
  • " It is undisputed that the non-admittance as such was already known to the petitioner during the oral proceedings. It is also apparent from the minutes that the petitioner already had multiple opportunities to formulate a proper objection under Rule 106 EPC during the oral proceedings. Following the decision on the admittance, other issues were still under discussion. The parties were also invited to comment before the Board announced its final decision, before the closure of the oral proceedings."

  • "[T]he [Enlarged] Board had no reason to assume that the petitioner's argument on the right to be heard was already a formal objection pursuant to Rule 106 EPC. A mere reference to the right to be heard does not immediately become an objection under Rule 106 EPC. It normally needs to be formulated after the alleged procedural irregularity and cannot be formulated prematurely; see R 14/11, Reasons 2.7 [] . For this reason alone, the Board did not have to assume in the course of the oral proceedings that the proprietor intended to make an objection under Rule 106 EPC, even if it did take note of the remark on the right to be heard during the discussion on the admittance."
  • "It is undisputed that the non-admittance as such was already known to the petitioner during the oral proceedings. It is also apparent from the minutes that the petitioner already had multiple opportunities to formulate a proper objection under Rule 106 EPC during the oral proceedings. Following the decision on the admittance, other issues were still under discussion. The parties were also invited to comment before the Board announced its final decision, before the closure of the oral proceedings."
  • Note, G 12/91 held that: "Where oral proceedings are held, the decision may be given orally. The decision becomes effective by virtue of its being pronounced. ... Once it has been pronounced ... the decision enters into force and cannot be amended, even by the department that issued it. " This holding should probably be understood in a nuanced sense for decisions on the admissibility of submissions announced in the course of the oral proceedings: they can be set aside by the Board in case of a persuasive objection under Rule 106 EPC
EPO 
The link to the decision is provided after the jump, as well as (an extract of) the decision text.

6 March 2024

T 1126/19 - The whole list as starting point

Key points

  • The decision was taken on 21.07.2023 and the written decision was issued on 03.01.2024. A communication under Art.15(9) was sent (link).
  • The file does not show any communication under Art. 15(9) RPBA to inform the parties about the delay, and the written decision itself does not acknowledge the delay in any way. 
    • One can only hope that compliance with Art. 15(9) RPBA will become more visible after the amendment of Art. 15(9) as of 01.01.2024. 
  • Is the starting point for an inventive step analysis under the problem-solution approach a single document, or a single embodiment of a document, or something else? 
  • "Claim 1 is directed to a camsylate salt of rucaparib which is crystalline and has a PXRD pattern comprising the characterising peaks 12.2±0.2, 14.8±0.2 and 22.4±0.2."
  • "The invention is based on the finding that crystalline rucaparib camsylate is particularly suitable for the preparation of solid dosage forms due to its physical stability and low hygroscopicity (paragraph [0045]). The patent identified three crystalline forms of rucaparib camsylate, which were designated as Forms A, B and C (paragraph [0054]). "
  • "claim 1 defines a rucaparib salt that contains Forms A and/or B, and [optionally] Form C."
  • "document D1 [is] the closest prior art. As set out in point 4.1 above, D1 relates to the use of rucaparib as a chemosensitiser: it is combined with chemotherapeutic agents for potentiating the effect of the latter in the treatment of cancer. In paragraph [0043], D1 discloses a list of about 60 pharmaceutically acceptable salts of rucaparib that can be used in therapy. The list includes camsylate, although the preferred salts are phosphate and gluconate."
  • "The parties agreed that D1 was the closest prior art but disagreed on whether inventive step should be assessed starting from the whole list in paragraph [0043] or the specific disclosure of the camsylate salt in that paragraph."
  • " The board agrees with the appellant-patent proprietor [] that the starting point should be the whole list rather than the specific option of the camsylate salt. As explained in decision T 970/00 (Reasons 4.1.2), cited by the appellant-patent proprietor, the disclosure of the closest prior art must be considered on the basis of its technical information, without distorting or misrepresenting it by the knowledge of the invention."
  • "In paragraph [0043] of D1, the camsylate salt of rucaparib is not singled out. D1 neither illustrates the camsylate salt of rucaparib nor presents it as a standalone embodiment. Paragraph [0043] is merely a notional disclosure in which camsylate is one among a long list of possible options, but not among the preferred ones. The isolation of one of the non-preferred options from paragraph [0043] would distort the teaching of D1, putting an inappropriate weight on that option."
  • "Starting from the list of pharmaceutically acceptable salts in paragraph [0043] of D1, the subject-matter of claim 1 differs in the selection of camsylate as the rucaparib salt and the additional requirements that the salt be crystalline and show three specific PXRD peaks."
  • "the board agrees with the objective technical problem proposed by the appellant-patent proprietor, i.e. the provision of a solid form of rucaparib having a suitable combination of properties for development into a solid dosage form."
  • " On the issue of obviousness, D1 does not deal with the formulation of solid forms of rucaparib. It contains no teaching on whether any of the salts in the long list of paragraph [0043] might possibly be suitable for preparing an oral solid formulation. The skilled person would have needed to study each of the salts for assessing: first, whether they are solid; second, how many solid forms they may adopt; and third, whether there are forms with properties suitable for a solid formulation."
  • As noted by the appellant-patent proprietor, it is common general knowledge that finding a salt of an active compound which has a balance of properties making it suitable for an oral solid formulation is generally a difficult semi-empirical task which requires non-routine experimentation and has an uncertain outcome. "
  • "the salt of claim 1 involves an inventive step and claim 1 meets the requirements of Article 56 EPC. "
EPO 
The link to the decision is provided after the jump, as well as (an extract of) the decision text.

4 March 2024

T 0552/22 - Functional features and G 2/21

Key points

  • G 2/21, r.74 held that for second medical use claims: " a technical effect, which in the case of for example a second medical use claim is usually a therapeutic effect, is a feature of the claim, so that the issue of whether it has been shown that this effect is achieved is a question of sufficiency of disclosure under Article 83 EPC. Hence, because the subject-matter of second medical use claims is commonly limited to a known therapeutic agent for use in a new therapeutic application, it is necessary that the patent at the date of its filing renders it credible that the known therapeutic agent, i.e. the product, is suitable for the claimed therapeutic application."
  • The present claim 1 is directed to a bacterial cell: " A bacterial cell to be stably cultured in a medium for the production of ...] fucosyllactose, the cell being transformed to comprise at least one nucleic acid sequence coding for a fucosyltransferase".
  • The present decision seems to illustrate that the rule of G 2/21 r.74 is not limited to second medical use claims.
  • In Examples 2 to 4, the protein SetA is used. The claim also covers SetB and SetC as the encoded fucosyltransferase.
  • "The board therefore agrees with the appellant [opponent] that if, according to the patent, it already came as a surprise that the SET protein with the broadest substrate specificity - SetA - exports fucosyllactose (see point 11. above), it was not demonstrated to the skilled person that SetB and SetC, having a narrower substrate specificity, also export fucosyllactose. Mentioning SetB and SetC in the patent therefore does not suffice to enable the skilled person to achieve the technical effect claimed over the whole ambit of the claim."
  • "The opposition division held that with SetA, the patent provided one way of working the invention; that it was not inherently implausible that fucosyllactose could be a substrate for SetB and SetC as well; and that post-published evidence D18 suggested that the invention could also be practised with SetB and SetC. The opposition division concluded that there was not sufficient doubt, supported by verifiable facts, that the person skilled in the art could work the invention over the whole scope of the claim."
  • "sufficiency of disclosure must be given at the effective date of the patent (see point 7. above), and post-published evidence is manifestly unsuitable for guiding the skilled person in carrying out the claimed invention on the effective date. Lack of disclosure on the suitability of SET family members for fucosyllactose export upon overexpression could not therefore be remedied by post-published evidence such as D18"
  • "To meet the requirement that the disclosure of the invention be sufficiently clear and complete for it to be carried out by the person skilled in the art, the patent would have to credibly disclose either that all SET family proteins lead to an export of fucosyllactose upon overexpression or provide the skilled person at least with sufficient guidance on how to select the SET family proteins that do lead to an export of fucosyllactose upon overexpression without undue experimentation "
  • As I understand it, the debate was not about whether the skilled person could m ake the cell with the genetic transformation as such, but whether the application asf filed made the functional feature credible over the whole scope of the (structural features) of the claim.

  • The auxiliary requests (which were carry-over requests from the first instance procedure) are not admitted because only the basis was indicated, which was considered to be insufficient substantiation (Art. 12(3) RPBA).  
  • "regarding the respondent's [proprietors] argument that the amendments made in auxiliary request 2 were self-explanatory in that they addressed the appellant's sufficiency of disclosure objection, the board notes that the appellant also raised objections as to lack of inventive step and that the respondent did not provide any explanation as to how the amendments made in auxiliary request 2 address these objections."
    •  As a comment, the proprietor may have considered the opponent's inventive step attack against the main request to be flawed. I don't see why an amendment should be responsive to all objections on file. 
  • The patent is revoked.




The link to the decision is provided after the jump, as well as (an extract of) the decision text.


1 March 2024

T2872/19 - Need to file and substantiate carry-over requests as respondent

Key points

  •  The opponent appeals the decision to reject the opposition. The Board finds the main request not inventive.
  • The Board turns to the auxiliary requests. "These auxiliary requests were introduced by reference to auxiliary requests and arguments provided in a letter filed in the first-instance proceedings, see the respondent's [proprietor's] reply to the appeal"
  • This reference to a part of a letter in the first  instance proceedings is seen as insufficient substantiation.
  • " The respondent [proprietor] argued that neither the decision under appeal nor the appellant's statement of grounds of appeal dealt with the first to sixth auxiliary requests. Therefore, the respondent concluded they could not be expected to provide any argument going beyond those contained in the letter referred to."
  • The Board:  However, this is not correct. A discussion of the auxiliary requests in appeal necessarily implies that auxiliary requests are on file in the appeal proceedings, which was not the case at the time the statement of grounds of appeal was filed. 
  • The auxiliary requests filed during first instance proceedings are not necessarily all maintained in appeal, so it cannot be expected of the opponent to address the auxiliary request filed in the first instance proceedings [in the Statement of grounds] without knowing whether they are maintained in appeal. 
  • The respondent-patent proprietor is expected to present reasons in the reply to the appeal as to why the auxiliary requests (either maintained requests from the first instance or new requests) overcome the specific objections raised in the statement of grounds of appeal against the main request. When the patent has to be amended, there is no longer a presumption of validity. The respondent therefore has to demonstrate that the auxiliary requests overcome the objections on file at the appeal stage. These do not necessarily correspond to objections presented in the first instance. This is consistent with the view expressed in decision T 1041/21, reasons 5.1.4."
    • A petition for review  is pending in T 1041/21.
    • In the present decision, an objection under Rule 106 was raised on the matter of the admissibility of the auxiliary request. 
EPO 
The link to the decision is provided after the jump, as well as (an extract of) the decision text.