2022 (Gyo-Ke) 10110 [Steel Pipe Sheet Pile Quay] <Miyasaka> — Obviousness of a mathematical formula at issue
Updated: 1 day ago
Article information
Article type: Case note
Category: Patents
Topics: Inventive step, Numerical limitations and parameters
First published on this website: 2026-11-01
Display and classification checked: November 2, 2026
Originally published on Ameblo: 2024-07-09 (Japan time). Full English translation.
2022 (Gyo-Ke) 10110 [Steel Pipe Sheet Pile Quay] <Miyasaka>
*The issue was the obviousness of a mathematical formula.
⇒ Inventive step: satisfied
“Exhibit Ko 1 … merely shows that a configuration relating to the formula for ρ … is theoretically possible … it is not found that deriving the formula for ρ … was easy … and this does not negate the inventive step of the configuration relating to the formula for ρ, which is a numerically limited invention.”
*For parameter/numerically limited inventions, merely showing that a mathematical formula is theoretically possible cannot negate inventive step!!
(Excerpt from the court's reasoning)
ρ（＝ＨＴ４／ＥＩ）＞0.412ｌｈ＋72.118…
In light of the common general technical knowledge at the time of the patent application …, it is difficult to find that an object satisfying the formula for ρ could reasonably have been designed using steel with a higher yield strength than SKY490 without using that formula; the existence of such an abstract possibility does not negate the inventive step of the configuration relating to the formula for ρ, which is a numerically limited invention. Figure 6.9 of Exhibit Ko 1 is found to apply irrespective of whether the piles are steel sheet piles or steel pipe sheet piles, just as the graph in Figure 2 applies to steel pipe sheet piles. However, this merely indicates that a steel pipe sheet pile quay satisfying the configuration relating to the formula for ρ is theoretically possible. It is not found that a person skilled in the art could readily have derived the formula for ρ from the graph in Figure 6.9 …, and this does not negate the inventive step of the configuration relating to the formula for ρ, which is a numerically limited invention.
Translator’s notes (editorial)
Editorial correction: “cannot negate obviousness” in the source commentary has been corrected to “cannot negate inventive step,” consistent with page 30 of the judgment.
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November 1, 2026: First published on this website.
November 2, 2026: Added article information, classification, topics, language navigation, related articles where the same case was confirmed, consultation guidance, and SEO. The original text and first-published date were preserved.
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