Texas Instruments Incorporated

The dispute in *Texas Instruments Incorporated v Commissioner of Patents* concerned an application for a patent by Texas Instruments Incorporated for a method of manufacturing semiconductor devices. The Commissioner of Patents had refused to grant the patent, and Texas Instruments appealed this decision to the Federal Court of Australia.

The primary legal issue before the Court was whether the invention, as described in the patent application, constituted a "manner of manufacture" within the meaning of section 6 of the Statute of Monopolies, which is the relevant test for patentability in Australia. Specifically, the Court had to consider whether the claimed method was a practical application of scientific principles that produced a useful result or an artificial state of affairs.

Justice Wilson reasoned that the Statute of Monopolies, and by extension the Patents Act 1990 (Cth), was intended to protect inventions that were practical and commercially useful, rather than mere scientific discoveries or abstract ideas. His Honour reviewed established case law, including *National Research Development Corporation v Commissioner of Patents*, which affirmed that a process or method could be a manner of manufacture if it involved a practical application of scientific knowledge to produce a tangible outcome. The Court found that the method described by Texas Instruments, which involved specific steps in the manufacturing process of semiconductor devices, was a practical and useful application of scientific principles, thereby satisfying the "manner of manufacture" requirement.

The Court allowed the appeal, setting aside the Commissioner's decision and remitting the matter to the Commissioner with a direction to grant the patent.