Tokyo District Court, Reiwa 7 (Wa) 70141 [Inactivated Vaccine Preparation and Method for Preventing Infectious Disease] <Presiding Judge Nakashima>
更新日：4 日前
Article information
Content type: Case note
Categories: Patents
Issues: Inventive step / Support requirement
First published on this site: 2026-10-03
Display and classification checked: 2026-10-03
Tokyo District Court, Reiwa 7 (Wa) 70141 [Inactivated Vaccine Preparation and Method for Preventing Infectious Disease] <Presiding Judge Nakashima>
① It would have been easy for a person skilled in the art to conceive of inactivating a strain publicly known before the priority date and using it as a vaccine.
⇒ Lacks inventive step.
② The wording of the claim is broad enough to encompass another strain (Type III) for which the specification discloses no effect.
⇒ Violates the support requirement.
(Excerpt from the judgment; translated from Japanese)
Certificate Ko 18 states “for vaccine prototyping and research,” and therefore can be said to disclose or suggest that “Lactococcus garvieae strain 121941” can be used for vaccine prototyping and research. Further, inactivating the causative bacterium can be said to have been common general knowledge.
What is disclosed in the specification is a vaccine preparation against streptococcosis caused by Type II; there is no disclosure of a vaccine preparation or effect against Type III.
Original article: https://lnkd.in/gSQZa669
Original source shown in the LinkedIn preview: https://www.courts.go.jp/assets/hanrei/hanrei-pdf-95718.pdf
Originally posted on LinkedIn: https://www.linkedin.com/feed/update/urn:li:activity:7511585491377410048/
Related articles
Update and correction history
Dated entries are added for corrections, supplements, classification, display, and related-article changes, separately from the first publication date.
2026-10-03: First publication on this site from the LinkedIn original.
Consultation guide by purpose: https://www.takaishihideki.com/en/single-post/consultation-guide-en
