2020 (Gyo-Ke) 10144 [Infusion Preparation Containing Sulfur-Containing Compounds and Trace Metal Elements] <Honda> — Not “Obviousness upon Obviousness”
更新日：3 日前
Article information
Article type: Case note
Category: Patents
Topics: Inventive step
First published on this website: 2026-11-01
Display and classification checked: November 2, 2026
Originally published on Ameblo: 2024-08-24 (Japan time). Full English translation.
2020 (Gyo-Ke) 10144 [Infusion Preparation Containing Sulfur-Containing Compounds and Trace Metal Elements] <Honda>
Difference A concerns the “composition of the solution.”
Difference B concerns the “contents and manner of storage.”
⇒ The two differ in technical perspective.
⇒ Even if the differences are identified separately,this is not “obviousness upon obviousness.”
(*The ultimate conclusion was that inventive step was satisfied.)
(Excerpt from the court's reasoning)
…The defendant argues that Differences A1-1 and B1-1 should not be identified separately. However, Difference A1-1 concerns the composition of the amino-acid-containing solution, while Difference B1-1 concerns what is contained in a container stored in one chamber of a multichamber infusion container and how that container is stored. The two thus differ in technical perspective. The points relied upon by the defendant merely constitute circumstances supporting the view that the configurations of the corrected inventions relating to Differences A1-1 and B1-1 should be understood as part of a cohesive technical concept constituting one cited invention….
<<⇒ Ultimately neither difference was obvious; inventive step satisfied.>>
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