26 April 2024

T 1625/21 - Shuffling auxiliary requests in appeal

Key points

  • Some auxiliary requests were admissibly filed before the OD and were substantiated in the proprietor's statement of grounds. The OD had maintained the patent in amended form. Can the Board hold these auxiliary requests inadmissible? 
  • If yes, on what ground?
  • The answer is that the requests were renumbered in appeal, from Auxiliary Requests 8-9 before the OD to requests 3-4 in appeal. I understand that AR-1 before the OD was filed during the oral proceedings before the OD (see the minutes), was held allowable by the OD, and was narrower than AR's 8 and 9.  
  • The Board, in German: " Diese Anträge sind aus im Wesentlichen den gleichen Gründen nicht zulässig, da sie auf den erstinstanzlichen Hilfsanträgen 8-9 (in der mündlichen Verhandlung umnummeriert zu Hilfsantrag 9 bzw. 10) beruhen, die die Patentinhaberin zugunsten des damaligen Hilfsantrags 1 der Einspruchsabteilung nicht zur Entscheidung vorgelegt hat. Auch diese Anträge versuchen die Einschränkung auf w-Wert zwischen 20 und 40 (Hilfsantrag 5) bzw. auf die Verwendung des nichtionische Tensids (Hilfsantrag 3 und 4) rückgängig zu machen bzw. durch andere Einschränkungen zu ersetzten. Einsprechende Anträge hätten jedoch bereits erstinstanzlich eingereicht werden können und sollen (Artikel 12(4) und (6) VOBK)." 
EPO 
The link to the decision is provided after the jump.

24 April 2024

T 0600/21 - Admissibility, complexity, and matters the OD did not arrive at

Key points

  • The Board decides not to admit AR-3 in this opposition appeal.
  • The proprietor filed these requests in their reply to the appeal of the opponent. The Board in machine translation notes that: "it did not explain which objections the respective changes address and why the changes are suitable for overcoming the objections raised against the main application. Without this information, the requirement of Article 12(3) RPBA that the response to the complaint must contain the respondent's complete complaint is not fulfilled, unless the changes are self-explanatory in this respect. However, this is not the case." 
  • The amendment is limiting the claimed detergent composition to a solid detergent composition.
  • The Board: "solid dishwashing detergents are undisputedly part of the state of the art, so it is not self-explanatory why the inclusion of this feature eliminates the objection of lack of inventive step." (the higher ranking request was rejected as obvious over D12).
  • The Board, however, also acknowledges that D12 is about liquid detergents, not about solid detergents. The Board does not explain why it is not self-evident that an amendment that changes the closest prior art is not a suitable amendment in reply to an inventive step attack.
  • The Board notes that if these auxiliary requests are admitted, then D25 filed by the opponent also has to be admitted, and inventive step starting from D25 has to be discussed. This would run against procedural economy and would be a further reason for not admitting the auxiliary request under Article 12(4) RPBA.
  • The Board does not indicate that the amended claim would be obvious starting from D12. In fact, the need to consider inventive step starting from D25 speaks against this, it seems to me.
  • The Board does not indicate that the amended claims should have been submitted in the first instance proceedings under Art. 12(6).
  • The Board does  not (or at least not explicitly) acknowledge that Art. 12(4) fifth sentence, mandates the consideration of all three of the following factors: "The Board shall exercise its discretion in view of, inter alia, (i) the complexity of the amendment, (ii) the suitability of the amendment to address the issues which led to the decision under appeal, (ii) and the need for procedural economy." (emphasis and numerals added).
  • The Board does not consider, or at least not explicitly, factor (ii), which is the only factor in the list that is by its nature in favour of admitting any amendment (i.e. a high score on factor (ii) is a reason for admitting the amendment, a high score of factors (i) and (iii) is a reason for not admitting the amendment).
  • The analysis that the responsive filing of D25 by the opponent can be considered under the factor complexity (factor i) seems in line with Müller and Mulder's Proceedings before the European Patent Office, 2nd ed., 2020, p.125.  
  • The OD found the set of claims inventive over D12. So, the OD would not have arrived at the amended set of claims even if AR-3 had been filed before the OD, and the Board would have no reasoning by the OD to review, it seems to me. The filing of AR-3 at the beginning of the appeal, in that sense, does not add procedural complexity, compared to the case where it would have been filed before the OD. Moreover, the OD would have no reason to consider inventive step over D25 for a request that it would not have arrived at had the request been pending in the first instance proceedings (at least the OD would not have to include any reasoning on that point in the decision because the OD considered a higher-ranking request to be allowable). So, introducing D25 in appeal does not seem to increase complexity. 
  • As I understand it, AR-3 was the highest-ranking request after the set of claims held allowable by the OD. 
  • The application was filed in 2005 as a PCT application and granted in 2018.


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

22 April 2024

T 1656/17 - Dealing with a partiality objection

Key points

  • This decision was issued in October 2023 after a five-year appeal procedure (but with a separate decision on a partiality objection). The grant was in 2014. The PCT filing date is in 2008. A petition for review is pending.
  • The first oral proceedings took place on 5 July 2022. The Board concluded that claim 1 was obvious over D10. The oral proceedings were adjourned to 14 July 2022, as vico, with the consent of the parties.  The appellant/proprietor withdrew his consent on 8 July. Oral proceedings were resumed on 21 October 2022 after a new summons. 
  • The Board refused to reopen the debate, giving rise to a first objection under Rule 106.
  • Two further objections were raised under Rule 106.
  • " The oral proceedings were interrupted at 17.49 hrs for deliberation by the board on the admittance of documents D38a, D46, D47 and D48.
  • " At 18.20 hrs, one of the respondent's representatives entered the room where the board was deliberating and closed the door behind him ("the room incident"). He asked about the timetable of the oral proceedings on that day as the respondent's representatives had to catch a plane to London. The chair immediately asked him to leave the room as the board was deliberating, adding that the parties would be called in in a few minutes. The representative immediately left the room at 18.21 hrs." 
  • A new objection under Rule 106 was filed by the proprietor.

  • On 27 October 2022, the board issued summons to in-person oral proceedings, according to which the oral proceedings were to be resumed on 11 January 2023."  These summons were for three days.

  • By letter dated 28 December 2022, the appellant raised objections of suspected partiality under Article 24(3) EPC against the members of the board." 

  • On 11 January 2023, at 14.05 hrs, the oral proceedings before the board in its original composition were interrupted and an alternate board was appointed. After the alternate board decided [on 12 January, with oral proceedings before the alternate Board on 11 and 12 January] that the objection of suspected partiality against the members of the board in its original composition be refused, the oral proceedings before the board in its original composition were resumed on 13 January 2023, at 9.02 hrs. 

  • At 09.04 hrs, shortly after the resumption of the oral proceedings before the board in its original composition on 13 January 2023, the appellant filed the following objection under Rule 106 EPC" 

  • At 16.53 hrs, the appellant filed a further objection under Rule 106 EPC ("objection 6"), which reads as follows: ..." 

  • The Board, on 13 January 2023, dismissed the appeal.

  • The Board issued the decision, 173 pages in writing, in October.


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

19 April 2024

T 2175/15 - The opponent submits five partiality objections

Key points

  • Three interlocutory decisions on partiality were issued in September 2023 in this opposition appeal case, where the opponent has, up to now, filed five partiality objections. 
  • The decisions are anonymised, but the application number is easy to find and the file is public (some letters are redacted). 
  • The appeal was filed in November 2015, the statement of grounds was in January 2016, and the reply was filed in May 2016, followed by the silence of the Board until April 2019: summons for oral proceedings to be held on 20 March 2020 (bad luck). 
  • Oral proceedings were postponed and finally held by vico in January 2021. The Board admits auxiliary requests and decides that the proceedings continue in writing.
  • The opponent, represented by a professional representative of a German firm, files a first partiality objection in April 2021, followed by a second one when the Board, in original composition, outlines the framework for admissibility. The second objection is rejected by the Board in alternate composition.  The Board, in the original composition, issues a new summons with a preliminary opinion on the remaining issues of the admissibility first partiality objection and the apportionment of costs (the patentee had withdrawn the appeal). The opponent files a third partiality objection. Again, a Board in alternate is then formed, and the opponent files a fourth partiality objection against one of the members of the Board in alternate composition. A replacement Board member was appointed, and the opponent filed a fifth partiality objection. A further replacement member is appointed. Oral proceedings are held in June 2023 before the Board in alternate composition.
  • The second objection was dismissed in  April 2022, and now the 3rd, 4th and 5th. 
  • The decision on third objection was taken by Board members N, D, H; the decision on the fourth objection by K, D and H, the decision on the fifth objection by G, D and H, all on the same day. Must have been an interesting set of oral proceedings on 23 June 2023. However, the minutes are not visible in the online file.
  • The register shows that a petition for review R 16/22 is pending against the decision of April 2022, though the documents about that petition are not visible in the online file. 
  • The appeals were withdrawn on 4 and 7 July 2022 but the opponent maintained its request for cost apportionment. 
  • There was some litigation about the national German patent. I understand that there was some German  case law that a preliminary injunction could not be awarded by German courts until the validity of the patent was proven in opposition (or nullity) proceedings (see CJEU case C-44/21 of April 2022). So, possibly, the opponent had no clear interest in a swift end to the opposition proceedings at the relevant times.
EPO 
The link to the decision is provided after the jump.


17 April 2024

T0481/21 - OD selects CPA, other attacks not abandoned

Key points

  • The opponent appeals.
  • " the appellant formulated an objection against the then pending main request starting from document D1 as the closest prior art. The proprietor argued that this objection should not be admitted because the only document cited as closest prior art in the appealed decision was D5, so this objection was not part of the appealed decision under Article 12(2) RPBA.
  • "The Board however notes that document D1 was extensively discussed both under novelty and under inventive step in the first instance proceedings. "
  • "It is apparent from the contested decision and the minutes that at the oral hearing document D1 was discussed in order to assess the novelty of the method and the product claims. As also explained in the minutes, D5 was however considered as representing the closest prior art because it addressed the same technical problem and had certain features in common with the invention."
  • "Since there is no indication that the inventive step objections starting from D1 discussed during the written proceedings were explicitly or implicitly abandoned at the oral hearing, they are effectively part of the first instance proceedings, implying that the appealed decision was at least implicitly based on them as required by Article 12(2) RPBA. In particular, the Board considers that the decision to contemplate D5 as the closest prior art implicitly involves the selection of D5 over D1 as closest prior art, which does not imply that the objections starting from D1 were no longer maintained, but simply that it was decided (in view of the conclusions on novelty in view of D1) that D5 represented a more promising springboard. Since the inventive step objection is considered to be part of the first instance proceedings, there is no basis not to admit this objection under Article 12(4) and (6) RPBA."
  • The patent is revoked.
EPO 
The link to the decision is provided after the jump, as well as (an extract of) the decision text.

16 April 2024

J 0003/23 - (Not) remedying formal deficiencies in the drawings

Key points


  • An application is refused because a deficiency in the drawings was not corrected in time in reply to a communication of 24.08.2021 under R.58, setting a two-month time limit. 
  •  "On 15 December 2021, the appellant (applicant) submitted ten pages with the corrected ten drawings".
  • "By decision of 21 December 2021 (which was handed over to the EPO postal service on 14 December 2021), the Receiving Section refused the application pursuant to Article 90(5) EPC because the deficiencies had not been corrected in due time."
    •  As a comment, I think a fair and reasonable application of the EPC would be to make the decision based on an ex nunc examination, i.e., based on the file's status as it was on the decision day. In other words, the corrected drawings could and should have been accepted. However, the current position in the case law might be different.
  • The applicant requests re-establishment. The Receiving Section refuses the re-establishment.
    • Note that under J 18/08, the applicant could also have filed an appeal and then filed the drawings (again) with the Statement of grounds as a safe remedy (as I understand it, the principle to J18/08 applies to all refusals of applications for formal deficiencies).
    • The applicant could also have filed a divisional application during the period for filing an appeal, which is probably cheaper (only the filing fee; the search fee will be refunded in the parent case)
  • The applicant appeals the refusal of the re-establishment.
  • The appeal is inadmissible for lack of substantiation.
  • By way of obiter remarks, the Board also indicates that the appeal is not allowable even when reviewing the applicant's submissions before the Receiving Section.

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

15 April 2024

T 0273/23 - Purpose of the method

Key points

  • The decision in this appeal against a refusal was taken rather fast: statement of grounds filed 08.02.2023 (by a professional representative), oral proceedings held 27.10.2023. The applicant is a natural person (and a patent attorney).
  • Claim 1 in machine translation: "Method for positioning an art object (1) on a flowing body of water, wherein the art object (1) comprises two or more buoyant elements (3, 3 '), and at least one of the elements (3) is anchored at a position defined in the direction of flow and the other elements (3') are either also anchored or connected to one element (3)."
  • The applicant argues that claim 1 is novel over D5 because in D5, the art object is positioned in a bay, which is not a flowing body of water. 
  • Of note (in machine translation): "The CNN report (D5) on the artistic work "SOS (Safety Orange Swimmers)", which has been freely available to the public on the Internet since October 13, 2016, undisputedly constitutes prior art in accordance with Article 54(2) EPC represents. This report was introduced into the appeal proceedings by the Chamber with the notification pursuant to Article 15(1) RPBA dated April 12, 2023.
  • The Board: "The claimed method according to claim 1 mentions positioning in flowing water only as part of a purpose of the method ("for positioning an art object on a flowing body of water"). The procedure is therefore not limited further than by the suitability in this regard. It is therefore anticipated by any other positioning method of an art object, which is inherently suitable for being used for positioning in or on a river."
    • Compare Guidelines, F-IV, 4.13: "Where the stated purpose defines the specific application of the method, this purpose requires additional steps which are not implied by or inherent in the other remaining steps defined in the claim, and without which the claimed process would not achieve the stated purpose. Hence a method claim that defines a working method which, for example, commences with such words as "Method for remelting galvanic layers", the part "for remelting ..." is not to be understood as meaning that the process is merely suitable for remelting galvanic layers, but rather as a functional feature concerning the remelting of galvanic layers and, hence, defining one of the method steps of the claimed working method (see T 1931/14 and T 848/93)."
    • "On the other hand, where the purpose merely states a technical effect which inevitably arises when carrying out the other remaining steps of the claimed method and is thus inherent in those steps, this technical effect has no limiting effect on the subject-matter of the claim. For example, a method claim concerning the application of a particular surface active agent to a specified absorbent product and defining its purpose as "for reducing malodor" in terms of an intended technical effect is anticipated by a prior-art document describing a method having such suitability "for reducing malodor" although not mentioning the specific use"
    • The Board cites T 1931/14 and reasons, in machine translation: "a purpose (here the positioning of an object in a flowing body of water) does not have a restrictive effect if this effect inevitably arises when exercised of the remaining steps of the claimed method. However, anchoring an object ultimately always leads to a fixed position of this object, so that no further (implicit) features are associated with the anchoring beyond the positioning of the object."
    • The claim is held to be not novel.
    • As a comment, it's not clear to me why the method is not considered to involve an implicit step of placing the art object in a flowing body of water. 
EPO 
The link to the decision is provided after the jump, as well as (an extract of) the decision text.

  


12 April 2024

T 0229/18 - The Chair retires before the written decision is given

Key points

  • The decision was given during oral proceedings on 07.10.2021. Minutes were issued on 22.10.2021.
  • A notice about a transfer of the case to another Board was issued on 12.07.2022.
  • A party enquires in 2022 and later in September 2023 about when the written decision will be issued.
  • By that time, the chair had retired (in June 2022). The other party proposes that the Board apply Art. 8(3) RPBA, which states that if the Chair is unable to act, the longest-serving member shall sign the decision.
  • The Board issued a Communication on 23.10.2023, apologizing for the undue delay and mentioning "unfortunate circumstances and the productivity objectives imposed on the boards of appeal".
  • The decision in PDF was authenticated by the legal member instead of the Chair.

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


Unsupervised mode

  • This blog will run in unsupervised mode for the next few weeks and only with pre-scheduled posts. 
  • The follow.it email notifications will be sent out automatically as well. 
  •  Comments can be posted, but it may take some time before I approve them. 

10 April 2024

T 1920/21 - A tutorial on diagnostic methods

Key points


  • "The Enlarged Board of Appeal stated in G 1/04 (Conclusion 1) that to be excluded from patentability [under the diagnostmic method prong of Art. 53(c)] the claim is to include the features relating to: (i) the diagnosis for curative purposes stricto sensu representing the deductive medical or veterinary decision phase as a purely intellectual exercise, (ii) the preceding steps which are constitutive for making that diagnosis, and (iii) the specific interactions with the human or animal body which occur when carrying those out among these preceding steps which are of a technical nature." 
  • "the method steps of a technical nature belonging to the preceding steps which are constitutive for making the diagnosis for curative purposes stricto sensu must satisfy the criterion "practised on the human or animal body" [in order to be excluded]
  • The preceding method steps which are constitutive for making the diagnosis for curative purposes include:  (i) the examination phase involving the collection of data, (ii) the comparison of these data with standard values, (iii) the finding of any significant deviation, i.e. a symptom, during the comparison

  • " To determine whether claim 1 is directed to a diagnostic method within the meaning of  Article 53(c) EPC and thus excluded from patentability, it must first be established whether all of the necessary method steps (see point 3. above) are included in the claim."

  • The Board finds that this is the case.

  • The claimed method is a breath test.

  • "the Enlarged Board held that activities falling within steps (ii) and (iii) are predominantly of a non-technical nature, and in any event, are not normally practised on the human body (G 1/04, Reasons 6.4.1). Therefore, in most cases only the first phase which relates to the examination phase and the collection of data can be of a technical nature and, therefore, concerned with the criterion "practised on the human or animal body"."

  • "to satisfy the criterion "practised on the human or animal body" it is however not required that a preceding step of a technical nature be invasive. It suffices that its performance implies any interaction with the human or animal body, necessitating the presence of the latter (G 1/04, Conclusion 4). Collecting a breath sample necessarily requires the presence of the patient from which the breath sample is collected. The two technical steps of claim 1 relating to the collection of breath samples (see point 11. above) therefore satisfy the criterion "practised on the human or animal body"."

  • "the board is however satisfied that the further method step of a technical nature of phase (i), i.e. "measuring the content of **(13)C in the CO2 of the first and second sample and determination of a **(13)C/**(12)C ratio by spectroscopy in the respective samples" does not meet the criterion "practised on the human or animal body"."

  • The devices for measuring the 13C content " include devices for gas isotope ratio mass spectroscopy or infrared spectrometer (see also paragraph [0013] of the application) and are in any case devices which analyse the collected breath samples without any interaction with the patient or necessitating its presence."

  • Hence, the method escapes the exclusion by reciting one in vitro step.

  • "the Enlarged Board held in G 1/04 that since a narrow interpretation of the scope of the exclusion from patentability under Article 52(4) EPC 1973 [Art. 53(c) EPC 2000] in respect of diagnostic methods was equitable, it was justified to require that the performance of each and every one of the method steps of a technical nature of a diagnostic method should satisfy the criterion "practised on the human or animal body" (Reasons 6.4.4)."

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

8 April 2024

T 2004/21 - A new kind of alternative problem

Key points


  • This decision provides an important refinement of the problem-solution approach, especially for the case of problem inventions. 
  • Claim 1 is directed to a chewing gum comprising a base and "a blend of granules consisting of erythritol"
  • The claimed chewing gum differs from that disclosed in  D2 [the closes prior art] [...] in that: 1) the blend of erythritol granules comprises 50 to 99 wt% of coarse granules which are retained on a sieve of 250 microns" and in that the amount of erythritol granules is at least 20 wt.%
  • " The [proprietor] respondent argued that chewing gums containing fine, coarse or a blend of fine and coarse erythritol granules induced a sensation of hydration, i.e. a mouthwatering effect in the consumer. "
  • " The board agrees with the appellant [opponent] that the tests in the patent do not make it credible that a higher proportion of coarse granules enhances the mouthwatering effect. It considers, however, that, as argued by the respondent [proprietor], the overall picture emerging from the results makes it credible that the inclusion of erythritol granules in a chewing gum induces a mouthwatering effect."
  • The Board: "not all chewing gums induce a mouthwatering effect. In fact, paragraph [0003] of the patent teaches that certain chewing gums containing sweeteners may induce a sensation of dry mouth and the need to drink water. This makes it credible that the mouthwatering sensation induced by the tested chewing gums is due to the presence of the erythritol granules and that this effect can be achieved with both coarse and fine erythritol granules."
  • "The appellant argued that mouthwatering was an inherent property of the chewing gum of D2 and that this document already provided a solution to the problem of providing a chewing gum inducing mouthwatering. Since there was no evidence that the claimed chewing gum induced a stronger mouthwatering effect than that of D2, the underlying objective problem was merely "the development of an alternative chewing gum [according to the opponent]".
  • The Board: "Under the established case law, if a known problem has already been solved by the prior art and the claimed subject-matter represents a different solution to that problem, the objective technical problem should be formulated as the provision of an "alternative solution" to the known problem ([CLBA] I.D.4.5, "Alternative solution of a known problem"). 
  • However, the situation in the current case is different. Although the chewing gum of D2 has "inherent" mouthwatering properties, D2 discloses neither these properties nor the problem of providing a mouthwatering effect in a user. "Mouthwatering" is not mentioned in any of the cited prior-art documents. The claimed chewing gum can therefore not be considered an alternative solution to a known problem."
  • "Formulating the problem as the provision of an "alternative chewing gum" which is meant, explicitly or implicitly, to solve the problem of inducing mouthwatering would imply that this problem, as well as its solution, was known at the filing date. This would require reading into the teaching of D2 the technical contribution wich the patent makes over the prior art, namely the finding that erythritol granules induce a mouthwatering effect. "
  • "For these reasons, starting from D2, which discloses chewing gums preventing an abrasive sensation, the underlying objective technical problem is to be formulated as the provision of a chewing gum inducing a mouthwatering effect in a consumer."
  • "none of the cited prior-art documents mentions the problem of providing a chewing gum providing a mouthwatering effect. This problem was apparently not even known at the filing date."
  • "the skilled person confronted with the underlying problem would have had neither any reason nor guidance to prepare the claimed chewing gum by increasing the amount of coarse particles in the chewing gum of D2."
  • The claim is held to be inventive. 
EPO 
The link to the decision is provided after the jump, as well as (an extract of) the decision text.

5 April 2024

T 0842/22 - Not admitted ground admitted in appeal

Key points

  • New grounds of opposition can only be admitted in appeal with the consent of the proprietor.
  • What if the OD held a ground of opposition inadmissible?
  • " Appellant 2 argued, for the first time, five days before the oral proceedings before the opposition division (with letter dated 2 July 2021), that claim 1 defined, after the amendment, a cam with [certain features]".
  • "The opposition division noted that the grounds according to Article 100(c) EPC had not been raised before and that therefore the above objection introduced a fresh ground of opposition. Having found that the above objection was not prima facie relevant, the opposition division decided not to admit it into opposition proceedings."
  • "In the present case, however, the Board exceptionally follows the arguments of [opponent] appellant 2, requesting to set aside the discretionary decision of the opposition division and to admit its objection of added subject-matter, for the following reasons."
  • " The Board concurs with appellant 2 that clarity is not the correct basis for assessing added subject-matter and further that the above interpretation is not reasonable, as it goes beyond the literal meaning of the contentious feature, and against the general principles set out in the case law (CLB, II.A.6.1), according to which the wording of a claim should be read and interpreted on its own merits and given its broadest technically sensible meaning."
  • "In view of the above, the Board concludes that the opposition division, when taking the discretionary decision not to admit the late-filed objection of added subject-matter, did not apply the criterion of prima facie relevance in a reasonable way. Hence, the late-filed ground of opposition based on Article 100(c) EPC was wrongly not admitted into the proceedings by the opposition division and is to be considered as forming part of the legal and factual framework of the appeal proceedings."
  • The case is not remitted.
  •  "the main request cannot be allowed"
  • The patent is maintained based on an auxiliary request. 
  • The point is somewhat controversial; see CLBA  C.A.3.4.5. The approach of the present decision seems correct to me. 
EPO 
The link to the decision is provided after the jump, as well as (an extract of) the decision text.


4 April 2024

T 2095/21 - Strawman opponent and Art.15(9) RPBA

Key points

  • The decision was taken on 10.10.20213 and issued in writing on 28.03.2024. The public online file shows no items between 13.10.2024  2023(the minutes) and 28.03.2024 (the decision) as of the date of writing (02.04.2024). Hence, no Communication to the parties under Art. 15(9) RPB (to be issued at the end of the three-month period, i.e. by 10.01.2024) is visible. Was the President of the Boards informed (as is required under amended Art. 15(9), which entered into force on 01.01.01.2024)?  
    • Note, possibly the delay was for good reason in the case. And possibly the parties were informed with a notification that is in the non-public part of the file. 




  • The opponent is a patent attorney firm. 
  • "The appellant [proprietor] submitted that the representative firm was no longer the legitimate opponent because during the oral proceedings before the opposition division they openly admitted that they acted on behalf of a third party. This open admittance not only constituted clear evidence that the opposition was inadmissible, but also created confusion as to the opponent's actual identity. " 
  • " The board does not agree with this argumentation. As clarified by decisions G 3/97 and G 4/97 an opposition is not inadmissible purely because the entity named as opponent is acting on behalf of a third party."
  • "as it was clarified in G 3/97 and G 4/97 (Headnote 1(d)): "...a circumvention of the law by abuse of process does not arise purely because: a professional representative is acting in his own name on behalf of a client...". The filing of an opposition by a straw man is not as such an abuse of process, but it would require additional facts and evidence, as for instance if it were shown that the representative was acting on behalf of the patent proprietor, or was lacking entitlement to act as a European professional representative. "
  •  The opposition was therefore admissibly filed (Article 99(1) in conjunction with Rules 76 and 77 EPC).
EPO 
The link to the decision and (an extract of) the text of the decision are provided after the jump.

3 April 2024

T 1823/23 - Dropping the drawings in the Rule 71(3)

Key points

  • "The communication under Rule 71(3) EPC however referred to the description and the claims but not to the drawings."
  • The applicant realizes the error only after the grant and files a timely appeal.
  • "In the present case, the documents indicated in the communication under Rule 71(3) EPC are however manifestly not in line with those resulting from the examination of the request on file, because the drawings formed part of the application as filed but were never withdrawn by the (now) appellant, and only the claims and the description were objected to by the examining division and amended by the appellant, but not the drawings."
  • "In the case at issue, the communication under Rule 71(3) EPC does not contain any hint that any deletion or amendment were made by the examining division to the drawing sheets. There is thus a clear discrepancy between the description referring to the Figures and the absence of any drawing sheets in the text intended for grant, which should have been remarked upon by the examining division when allegedly deleting the drawing sheets, but apparently neither the members of the examining division nor the (now) appellant realised that the drawing sheets were missing and that the documents referred to in the communication pursuant to Rule 71(3) EPC did not correspond to those according to the appellant's request, which included the drawing sheets. Therefore, in line with decisions T 1003/19 and T 408/21, the board concludes that the examining division did not indicate in the communication according to Rule 71(3) EPC the text it intended to grant"
  • "The examining division therefore did not communicate the text that it intended to grant. Following T 2081/16 (point 1.4.5 of the Reasons), T 408/21 (point 1.12 of the Reasons) and T 1003/19 (point 2.4.5 of the Reasons), Rule 71(5) EPC correspondingly does not apply, as in the step preceding the deemed approval the applicant has to be informed of the text in which the examining division intends to grant the patent according to Rule 71(3) EPC. Although the (then) applicant received a Rule 71(3) EPC communication, the documents indicated were not those which the examining division intended to grant."
  • The appeal is allowable.
  • "The fact that a narrow interpretation of Rule 71(3) and (5) EPC as proposed by the present board allows for an appeal to be treated as admissible should however not be misinterpreted as an invitation to neglect the applicant's duty to carefully check the documents submitted in the text intended for grant sent with the communication under Rule 71(3) EPC. The request for reimbursement of the appeal fee is therefore rejected."
  • "The present board is aware of decision T 265/20"
EPO 
The link to the decision is provided after the jump, as well as (an extract of) the decision text.


1 April 2024

T 1216/23 - The SME reduction as a refund

Key points

  • This decision illustrates that if you are unsure if the SME reduction applies, you can pay a fee in full and request a partial refund.
  • The Board, in translation, under "On June 26, 2023, the amount of EUR 910.00 was repaid (the difference between the appeal fee paid of EUR 2,925.00 and the appeal fee of EUR 2,015.00 for a complaint filed by a natural person or a person referred to in Rule 6 (4) and (5) EPC is filed)."
  • In this case, interlocutory revision was granted. The request for full reimbursement of the appeal fee was forwarded to the Board. 
  • The applicant then withdrew the request for reimbursement.
  • The appeal proceedings are terminated without a decision and without (further) reimbursement. See T 0683/14. 

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

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.