Tokyo District Court, Case No. 2024 (Wa) 70129

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Article information

Article type: Case note

Display and classification checked: 2026-09-30

Categories: Patents

Topics: Proof of infringement / Litigation procedure

Published on this website: 2026-09-29

Tokyo District Court, Case No. 2024 (Wa) 70129

[Box-shaped vessel] (Presiding Judge Sugiura)

*The defendant denies involvement with the products at issue.

⇒ No "obligation to clarify the specific manner."

⇒ Claim requirements not satisfied due to insufficient proof.

The existence and locations of the "pH sensor" and "stock-solution supply device" in the products at issue are unknown.

Regarding Article 104-2 of the Patent Act (obligation to clarify the specific manner), the court held: "The defendant denies manufacturing and selling the defendant's products, which are box-shaped vessels, and also denies or disputes involvement with those products on the ground that its involvement is unclear. The only evidence supporting the defendant's manufacture, sale or involvement is the written statement in Exhibit Ko 8, and there is no objective evidence sufficient to establish it. In these circumstances, it cannot be said that 'its own acts,' whose specific manner the defendant must clarify under the above obligation, have themselves been identified."

(Quotations are translations.)

https://lnkd.in/gEcrMamC

https://lnkd.in/gXAZSMvu

hanrei-pdf-95627.pdf — courts.go.jp

Originally posted on LinkedIn: https://www.linkedin.com/feed/update/urn:li:activity:7510142137032740864/

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Updates and corrections

This log starts on 30 September 2026. Display and classification checks are distinct from a review of the legal analysis.

2026-09-30 — Presentation update: added the article type, this change log and a link to consultation options. The existing article text was preserved.

2026-10-01 | Name notation: replaced verified Japanese-script personal names with Roman-letter forms in this English article and its navigation. Legal analysis and original publication date unchanged.

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