2023 (Gyo-Ke) 10020 [Steel Pipe Pile Pier] <Honda>
更新日：3 日前
Article information
Article type: Case note
Category: Patents
Topics: Inventive step, Support requirement
First published on this website: 2026-11-01
Display and classification checked: November 2, 2026
Originally published on Ameblo: 2024-07-02 (Japan time). Full English translation.
2023 (Gyo-Ke) 10020 [Steel Pipe Pile Pier] <Honda>
*Although the specification described only examples under particular conditions, the court held, in light of the problem addressed by the invention, that “a person skilled in the art can … take other conditions into account and appropriately incorporate the above technical concept to solve the problems addressed by each invention at issue.”
⇒ Support requirement: satisfied
*The court rejected obviousness of locally increasing strength at particular locations.
⇒ Inventive step: satisfied
(Excerpts from the court's reasoning)
<Support requirement: satisfied>
The defendant argues that the specification merely states that verification was performed through seismic response analysis (simulation) under particular conditions (number of rows of steel pipe piles, water depth, ground structure, wall thickness and diameter of the steel pipe piles), and that it cannot be understood that adopting the numerical range for curvature φp would solve the problem under different conditions as well. Naturally, the ground and other circumstances where steel pipe pile piers are installed vary, and their performance must be verified by an appropriate method suited to the circumstances. What the specification discloses, however, is the technical concept of locally using steel pipe piles having deformation capacity of at least a specified value only at portions of the piles where the generated curvature is large in the underground portions of at least the piles positioned facing the landward side. When actually conducting performance verification such as seismic response analysis, a person skilled in the art who encounters this disclosure can take other conditions into account and appropriately incorporate that technical concept to solve the problems addressed by each invention at issue. Thus, the mere fact that only results under particular conditions are described does not provide a reason to conclude that the inventions fail to satisfy the support requirement….
<Inventive-step requirement: satisfied>
(Difference 3A) The “steel pipe piles” of Invention 3 are such that “among the steel pipe piles constituting the row of steel pipe piles, portions where the generated curvature is large in the underground portions of at least the steel pipe piles positioned facing the landward side, where the curvature arising in the piles in response to an external force is large, satisfy the relationship φp ≧ 5.65 × 10⁻³/D between the diameter D of the steel pipe piles and the curvature φp corresponding to their fully plastic moment, while the other portions of the underground portions of the steel pipe piles have lower deformation capacity than those portions,” whereas it is unclear whether the “steel pipe piles 9” of the invention in Exhibit Ko 1 have that configuration. …
…Even if ordinary design practice could involve progressively increasing the strength of steel pipe piles based on seismic response analysis results without using the curvature condition formula, it cannot be said that this would naturally lead further to locally placing high-strength steel pipe piles only at portions where the generated curvature is large. At least, it must be said that it is difficult to conclude that the configurations relating to Difference 3A or 3B could have been readily conceived.
Update history
The first-published date remains unchanged. Display maintenance, classification changes, related-article updates, and text corrections are recorded separately.
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.
