Tokyo District Court, Reiwa 2 (Wa) No. 4331 — Heated aerosol-generating device (Judge Nakashima)

Japanese version: https://www.takaishihideki.com/single-post/linkedin-7513746680962289664-ja

Article information

Article type: Case note

Categories: Patents

Issues: Support requirement

Published on website: 2026-10-08

Display/classification checked: 2026-10-10

Tokyo District Court, Reiwa 2 (Wa) No. 4331 — Heated aerosol-generating device (Judge Nakashima)

*Embodiments that cannot solve the problem are not included within the scope of the claims.

→ Support requirement satisfied.

(Excerpt from the judgment, translated)

…Even for other durations, it can be understood that the problems addressed by the claimed inventions can be solved by appropriately setting the other conditions, taking into account the common general technical knowledge at the filing date. The defendants point out that the inventions also encompass a first temperature of 360°C, a second temperature of 359°C and a third temperature of 360°C, or a heating duration of one second at each stage. However, a person skilled in the art would readily understand that conditions such as the first to third temperatures and the duration of heating at each stage should be appropriately set “so that aerosol is delivered more evenly during heating of the substrate” (…).

It cannot be said that a person skilled in the art, assuming numerical values such as those asserted by the defendants, would recognize that the claims include embodiments incapable of solving the problems addressed by the inventions.

https://lnkd.in/gRJR-VUy

Original article (2025-09-01):

https://lnkd.in/gVMrbM9n

Identical repost (2025-09-04):

https://lnkd.in/gkVT3dpy

Originally posted on LinkedIn: https://www.linkedin.com/feed/update/urn:li:activity:7513747031136448512/

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Update history

The update history records only changes actually published, with dates.

2026-10-08: First publication of the LinkedIn original; display, classification, and consultation link set.

2026-10-08: Added reciprocal related-article links.

2026-10-10: Updated related-article links. The original article text was not changed.

2026-10-10: Standardized related-article links to their published URLs. The original article text was not changed.