2024 (Ne) 10041 [Receiving Device] <Masuda>
更新日：6 時間前
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: 2025-10-02 (Japan time). Full English translation.
2024 (Ne) 10041 [Receiving Device] <Masuda>
*The counterpart to the subcombination claim does not impose any limitation on the configuration of the invention recited in the claim.
⇒ Not a matter specifying the invention (lack of inventive step).
[Claim 5] (Invention at issue)
A receiving device characterized by having an RFID interface for transmitting and receiving to and from the mobile telephone recited in Claim 4; transmission means for transmitting to that mobile telephone a request for the transmission of individual information; and determination means for determining whether individual information received from that mobile telephone is the requested individual information; and performing processing with that mobile telephone when the determination information received by the determination means is determined to be the requested individual information.
(Excerpt from the court's reasoning)
The corrected invention at issue is an invention of a “receiving device” in an invention of an overall apparatus consisting of a mobile terminal and a receiving device, namely an individual-information system; it is a so-called subcombination invention.
In a subcombination invention, it is necessary to ascertain what significance matters concerning another subcombination recited in the claim have in specifying the claimed invention from the standpoint of shape, structure, components, composition, operation, function, nature, characteristics, acts or actions, intended use, and the like (hereinafter “structure, functions, etc.”), and thereby delineate the technical scope of the invention. If matters concerning another subcombination specify only the apparatus of that other subcombination and do not specify any structure, functions, etc. of the apparatus recited in the claim, those matters concerning the other subcombination can be said to have no significance in specifying the claimed invention.
Turning to the corrected invention at issue, it is identified as an invention concerning a receiving device having an RFID interface for transmitting and receiving to and from the mobile telephone recited in Claim 4 (constituent requirement J′). The mobile telephone recited in Claim 4 is specified not only by that claim but also by Claims 1 and 3.
However, the descriptions in Claims 1, 3, and 4 all specify the structure, functions, etc. of the mobile telephone, not the structure, functions, etc. of the “receiving device.”
Accordingly, the matter “the mobile telephone recited in Claim 4,” which concerns another subcombination in the corrected invention at issue, can be said to have no significance in specifying the corrected invention at issue, which is an invention of a “receiving device.”
Therefore, in identifying the gist of the corrected invention at issue, it is appropriate to exclude the matter “(the mobile telephone) recited in Claim 4.”
Translator’s notes (editorial)
The quoted claim uses judgment/determination information in one place and individual information elsewhere. This variation is preserved, not silently harmonized.
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.
