Japanese Patent Case Summary: 2023 (Gyo-Ke) No. 10121 – Intellectual Property High Court (May 15, 2025)
“Imaging Apparatus”
Overview:
This case pertains to a decision to uphold an invalidation trial finding that a request for an invalidation trial is not established.
▶Summary of Judgement and Link to Full Text (Japanese)
Main Issue:
The main issue is whether or not there was an error in the determination of the trial decision finding that the description of the claims for this case was not in violation of the support requirements.
Summary:
In the trial decision, it was determined that, according to the detailed description of the invention stating that “in the hinge unit…, one first hinge…of the pair of first hinges…on the axis A which is located closer to the axis B is disposed between the pair of second hinges…on the axis B”, it is possible to reduce the size of the hinge unit, and thus it can be said that it falls within the scope in which a person skilled in the art can recognize that at least Problem 2 of the present invention (i.e., to provide an imaging apparatus capable of reducing the size of a hinge unit that movably connects a display to a main body) can be solved, and it cannot be said that the description of the claims is in violation of the support requirements.
In contrast, the plaintiff asserts that the length of a hinge bracket is always incorporated within the cover of the display, and thus the present invention does not contribute to a reduction in size compared to the invention of Plaintiff’s Exhibit 2, which is a prior art document. However, the court decision judged that, according to the disclosures in the specification and other documents for this case, the conventional technology disclosed in Plaintiff’s Exhibit 2 had a structure in which one of the “first hinges” connecting with the main body is not disposed between the “second hinges” of the axis perpendicular to the “first hinges”, so that a rectangular-parallelpiped space is left open between the “first hinges”, and if the display is assumed to be the same size, there would be a problem whereby the imaging apparatus increased in size by the amount of the rectangular-parallelpiped space, given this the present invention adopts a configuration in which “one of the pair of first hinges is disposed between the pair of second hinges”, for example, in claim 1, thereby hiding the axis comprising the pair of the first hinges inside the second hinges, so that the hinge unit is reduced in size, and if the display is the same size, it is clear that the imaging apparatus can be reduced in size by the amount of the rectangular-parallelpiped space formed between the first hinges in conventional technology.
Comments:
The examination guidelines stipulate that, in a case where multiple problems can be grasped from the disclosure of the detailed description of the invention, in order to determine that the description of the claims meets the support requirements, it is necessary that the solution to any one of those problems be reflected in the claims. The problems of the present invention are: (1) “a mechanism such as the pair of first hinges…is disposed so as to protrude to the outer side of the display…and is exposed to the outside of the digital camera, the design of the digital camera is damaged” (hereinafter “Problem 1”); and (2) “in the hinge unit…of the digital camera…, the axis A on which the pair of first hinges…are disposed intersects the axis B on which the pair of second hinges…are provided, at the outer side of the pair of second hinges…, the pair of first hinges…on the axis A are disposed so as to protrude to the outer side of the display…, and the hinge unit…is larger than the display…in view of such circumstances, and an object thereof is to provide an imaging apparatus capable of reducing the size of a hinge unit that movably connects a display to a main body” (hereinafter “Problem 2”). Concerning Problem 1, the matters defining the invention recited in claim 1 do not include any description that is equivalent to “cover” covering the hinge unit, and therefore, based on the wording of claim 1, a person skilled in the art cannot recognize that Problem 1 can be solved. However, concerning Problem 2, according to the detailed description of the invention stating that “in the hinge unit…, one first hinge…of the pair of first hinges…on the axis A which is located closer to the axis B is disposed between the pair of second hinges…on the axis B”, it is thereby possible to reduce the size of the hinge unit.
Hiroshi ABE