Tokyo District Court, 2020 (Wa) 22071 [Liquid Cleansing Agent for Removing Keratin Plugs] <Kokubu>
Updated: 6 hours ago
Article information
Article type: Case note
Category: Patents
Topics: Support requirement
First published on this website: 2026-11-01
Display and classification checked: November 2, 2026
Originally published on Ameblo: 2024-12-11 (Japan time). Full English translation.
Tokyo District Court, 2020 (Wa) 22071 [Liquid Cleansing Agent for Removing Keratin Plugs] <Kokubu>
*Although the problem section was amended, an abstract problem was not accepted.
⇒ Support requirement: not satisfied
“This is not affected … by the fact that, during prosecution …, an amendment deleted the wording ‘made to solve the above problem.’”
(Excerpts from the court's reasoning)
…Paragraph [0006] merely states that the invention's purpose is “to provide a liquid cosmetic capable of extracting proteins,” and says nothing about the presence or amount of surfactant or its effect on protein extraction. However, in the specification, [0006] and [0005] are positioned as descriptions of the “Problem to Be Solved by the Invention.” Paragraph [0005] states: “Because surfactants can burden the skin and cause roughness or the like, a method using no surfactant or an extremely small amount of surfactant was sought.” It is therefore reasonable to interpret the purpose in [0006] as premised on solving the prior-art problem described in [0005]. …
The invention's problem cannot be understood merely as providing a liquid cosmetic capable of extracting proteins; it is providing such a cosmetic capable of extracting proteins even without surfactant or with only a very small amount of surfactant….
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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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