IP High Court, Reiwa 7 (Gyo-Ke) 10085 [... Solar power self-consumption system] <Judge Nakahira>
更新日：4 日前
Article information
Article type: Case note
Category: Patents
Topics: Enablement, Inventive step, Motivation and teaching away
First published on this website: October 6, 2026
Case information: Reiwa 7 (Gyo-Ke) 10085 [... Solar power self-consumption system] <Judge Nakahira>
Display/classification checked: October 6, 2026
IP High Court, Reiwa 7 (Gyo-Ke) 10085 [... Solar power self-consumption system] <Judge Nakahira>
1. Enablement requirement
The court emphasized that the examples in the specification provide specific table values (e.g., β = 30 kW when 0 < α ≤ 20%) and explain their effects (avoiding reverse power flow and improving generation efficiency), and that the table is rewritable, with the idea of adjusting margins according to operation itself disclosed as part of the invention. It held that a person skilled in the art could implement this within the scope of ordinary design and adjustment, and that this could not be regarded as “undue trial and error.”
2. Inventive step
① Exhibits Ko 16–18 concern technologies in other fields—calculation of environmental burdens, assessment of component failure rates, and energy-saving management, respectively—with backgrounds different from the problems in Ko 1 of avoiding reverse power flow in photovoltaic generation and improving generation efficiency.
② These publicly known technologies disclose no specific motivation to “introduce a ratio obtained by dividing power consumption by the PCS rating and control the output upper limit by referring to a table according to that ratio” in the Ko 1 invention.
③ The Ko 1 invention uses coefficients a and b of a linear function as parameters and attempts to solve the problem by adjusting a and b within that framework. There is no necessity to replace that framework with ratio α and a table method.
⇒ The configuration pertaining to Difference 1-1 cannot be reached merely because “a ratio can be calculated using elementary mathematics”; technical motivation is lacking.
⇒ Inventive step affirmed.
Original article:
Related articles
Update history
This history records display, classification, and text changes made after publication on this website.
October 6, 2026: First published on this website from the LinkedIn original; article information, classification, topics, source, and consultation guide were added.
