Advanced Building Systems Pty Ltd v Ramset Fasteners (Aust) Pty Ltd

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HIGH COURT OF AUSTRALIA

BRENNAN CJ,
GAUDRON, McHUGH, GUMMOW AND KIRBY JJ

ADVANCED BUILDING SYSTEMS
PTY LIMITED & ANOR  APPELLANTS

AND

RAMSET FASTENERS (AUST) PTY LIMITED     RESPONDENT

Advanced Building Systems Pty Limited v Ramset Fasteners(Aust) Pty Limited (S19-1997) [1998] HCA 19

26 March 1998

ORDER

  1. Appeal allowed with costs.

  1. Orders of the Full Court of the Federal Court set aside.

  1. Matter remitted to the Full Court for determination of the remaining grounds of appeal to that Court and, if necessary, the redetermination of the cross-appeal to that Court.

On appeal from the Federal Court of Australia

Representation:

A J L Bannon SC with H R Sorensen for the appellants (instructed by Astridge & Murray)

R C Macaw QC with D M Yates for the respondent (instructed by
Davies Ryan De Boos)

Notice:  This copy of the Court’s Reasons for Judgment is subject to formal revision prior to publication in the Commonwealth Law Reports.

CATCHWORDS

Advanced Building Systems Pty Limited & Anor

v Ramset Fasteners (Aust) Pty Limited

Patents - Revocation - Whether an "invention" within meaning of Act - Relationship between obviousness and lack of novelty - Meaning of "inventive merit".

Patents Act 1952 (Cth), s 100.

BRENNAN CJ, GAUDRON, McHUGH AND GUMMOW JJ.

Introduction

  1. Standard Patent No 544832 ("the Patent") was issued under the Patents Act 1952 (Cth) ("the Act") to a United States corporation, The Burke Company ("the second appellant"), and was sealed on 28 October 1985. The term of the Patent was 16 years commencing on 27 August 1981. The basic application had been filed on 23 October 1980 and it is that date which provides the priority date by which questions of novelty and obviousness of the claims are to be assessed. By registered assignment dated 22 November 1990, the second appellant assigned the Patent to Advanced Building Systems Pty Limited ("the first appellant").

  2. The invention claimed in the Patent relates to hoisting attachments and methods for erecting prefabricated concrete walls on building sites.  There are two claims defining the invention.  The second is narrower than the first.  It is unnecessary for the issues which arise on this appeal to set out their text.

  3. In proceedings instituted in the Federal Court of Australia, the appellants alleged that Ramset Fasteners (Aust) Pty Limited ("the respondent") had infringed the claims of the Patent by the selling or supplying by way of hire of two lift systems for tilt‑up walls.  The components of these systems were described as the "Ramset Frimeda Rapid Lift System" and the "Ramset Face Lift Tilt Up System" ("the Ramset systems").

  4. The appellants also alleged that the respondent had failed to inform its customers that the use of components of the Ramset systems might infringe the Patent. This failure was alleged to constitute misleading or deceptive conduct within the meaning of s 52 of the Trade Practices Act 1974 (Cth) ("the Trade Practices Act"). By its defence, the respondent denied infringement and contravention of s 52 of the Trade Practices Act. The respondent…

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Details
Case
[1998] HCA 19
Decision Date

CaseChat Overview and Summary

The parties to this appeal were Advanced Building Systems Pty Ltd and Ramset Fasteners (Aust) Pty Ltd. The dispute concerned the validity of a patent held by Advanced Building Systems, which Ramset sought to revoke. The matter was heard by the High Court of Australia.

The central legal issue before the High Court was whether the invention claimed in the patent was an "invention" within the meaning of the relevant Act, specifically under section 100(1)(d). This question arose after the Full Court of the Federal Court had determined that the patent lacked "inventive merit," leading to its revocation. The Full Court's decision was based on its consideration of certain publications in Australia prior to the patent's priority date, which it found demonstrated that the claimed invention involved no inventive step.

The High Court allowed the appeal, setting aside the orders of the Full Court. The Court remitted the matter back to the Full Court for determination of the remaining grounds of appeal and, if necessary, a redetermination of the cross-appeal. The High Court's decision implies a disagreement with the Full Court's approach to assessing "inventive merit" and its application of the statutory provisions concerning patent validity.

Orders

Orders of the court

1.

Appeal allowed with costs.

2.

Orders of the Full Court of the Federal Court set aside.

3.

Matter remitted to the Full Court for determination of the remaining grounds of appeal to that Court and, if necessary, the redetermination of the cross-appeal to that Court.

Background

Background to the litigation

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Evidence

Evidence Before The Court

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Decision

Reasons for decision

KIRBY J (dissent)
So far as presently material, s 100 of the Act provides:"(1) A standard patent may be revoked, either wholly or in so far as it relates to any claim of the complete specification ... on one or more of the following grounds, but on no other ground:(a)that the applicant was not a person entitled to apply for the patent, so far as the invention is claimed in any claim of the complete specification ...;...(d)that the invention, so far as claimed in any claim of the complete specification ... is not an invention within the meaning of this Act;(e)that the invention, so far as claimed in any claim of the complete specification ... was obvious and did not involve an inventive step having regard to what was known or used in Australia on or before the priority date of that claim;(f)that the invention, so far as claimed in any claim of the complete specification ... is the subject of a valid claim of earlier priority date contained in the complete specification of a standard patent ...;(g)that the invention, so far as claimed in any claim of the complete specification ... was not novel in Australia on the priority date of that claim;(h)that the invention, so far as claimed in any claim of the complete specification ... is not useful;...(k)that the patent was obtained on a false suggestion or representation;(l)that the invention, so far as claimed in any claim of the complete specification ... was secretly used in Australia before the priority date of the claim;...(2) For the purposes of paragraph (1)(e) or (g), account shall not be taken of any secret use.(3) For the purposes of paragraph (1)(l), account shall not be taken of any use of the invention, so far as claimed in any claim -(a) for the purpose of reasonable trial or experiment only; or(b)by a department or authority of the Commonwealth, or of a State or Territory, or by a person authorized by such a department or authority, where the patentee, or a person from whom he derives his title, has communicated or disclosed the invention, so far as so claimed, to the department, authority or person."The judgments in the Federal Court The primary judge considered three advertisements published in Australia before the priority date and concluded in respect of each of them that it did not amount to an anticipation, that is to say, it did not render either claim of the Patent not novel in Australia on the priority date. His Honour identified the alleged anticipations as the Burke advertisement, the Frimeda advertisement and the RFA Systems advertisement in the English Concrete Year Book of 1980. Further, in the Complete Specification for the Patent under the heading "Description of the Prior Art", upon which the patentee claimed inventive improvements, it was stated:"The type of hoisting attachment with which the present invention is concerned is shown in US patent 3,883,170." As we have indicated above, the Full Court's judgment proceeded upon the basis of the abandonment at the trial of the allegations of obviousness and put to one side the issue whether the primary judge had erred in rejecting the case for invalidity based on the alleged anticipations[24]. Upon that footing, the Full Court nevertheless decided that the claims in the Patent did not have the "inventive merit" which, in the Full Court's view, was required for an invention within the meaning of the Act. It followed that the Patent was revoked under s 100(1)(d). In considering whether the invention claimed in the Patent was an "invention" within the meaning of s 100(1)(d), the Full Court said[25]:"In our view, for the reasons we have given, it is necessary to take into account the publications in Australia before the priority date. These are as follows:(a) the advertisement inserted by Burke into a United States publication;(b) the Frimeda advertisement in a 1977 German publication; and(c) the advertisement which appeared in The Concrete Year Book 1980, an English publication ...Once these publications are taken into account, we agree with his Honour's conclusion that the invention claimed in the Australian patent involved no inventive step.A combination patent may be valid even if each integer, when considered separately, is well known; but in that case the combination itself must be new".[24]Ramset Fasteners (Aust) Pty Ltd v Advanced Building Systems Pty Ltd (1996) 66 FCR 151 at 169.[25](1996) 66 FCR 151 at 167.

Ratio Decidendi

Legal Principle Established

Established by:

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