FEDERAL COURT OF AUSTRALIA
Tramanco Pty Ltd v BPW Transpec Pty Ltd [2014] FCAFC 23
Citation: Tramanco Pty Ltd v BPW Transpec Pty Ltd [2014] FCAFC 23 Appeal from: Tramanco Pty Ltd v BPW Transpec Pty Ltd [2012] FCA 613 Parties: TRAMANCO PTY LTD (ACN 010 101 872) v BPW TRANSPEC PTY LTD (ACN 006 645 272) File number: QUD 678 of 2012 Judge(s): ALLSOP CJ, GREENWOOD & NICHOLAS JJ Date of judgment: 13 March 2014 Catchwords: PATENTS – method for logging the performance of a vehicle suspension system – construction of phrase “impact loading of the vehicle” – sufficiency – novelty – obviousness – infringement – discussion of sufficiency requirements in relation to claims to methods for producing one or more specified results. Legislation: Patents Act 1990 (Cth) ss 7(3), 40(2)(a) Cases cited: Aktiebolaget Hassle v Alphapharm Pty Ltd (2002) 212 CLR 411
Britax Childcare Pty Ltd v Infa-Secure Pty Ltd (2012) 290 ALR 47
Flexible Steel Lacing Company v Beltreco Ltd (2000) 49 IPR 331
Jupiters Ltd v Neurizon Pty Ltd (2005) 222 ALR 155
Kimberly-Clark Australia Pty Limited v Arico Trading International Pty Limited (2001) 207 CLR 1
Kinabalu Investments Pty Ltd v Barron & Rawson Pty Ltd [2008] FCAFC 178
Kirin-Amgen Inc v Hoechst Marion Roussel Ltd [2005] RPC 169; (2004) 64 IPR 444
Lockwood Security Products Pty Limited v Doric Products Pty Limited (2004) 217 CLR 274
No-Fume Ltd v Frank Pitchford & Co Ltd (1935) 52 RPC 231
Olin Mathieson Chemical Corp v Biorex Laboratories Ltd [1970] RPC 157
Welch Perrin & Co Pty Ltd v Worrel (1961) 106 CLR 588
Wellcome Foundation Ltd v VR Laboratories (Aust) Pty Ltd (1981) 148 CLR 262Date of hearing: 2 and 3 May 2013 Place: Brisbane Division: GENERAL DIVISION Category: Catchwords Number of paragraphs: 229 Counsel for the Appellant: Mr A Franklin SC Solicitor for the Appellant: Bennett & Philp Lawyers Counsel for the Respondent: Mr P Collinson SC with Ms S Gatford Solicitor for the Respondent: Madgwicks Lawyers
IN THE FEDERAL COURT OF AUSTRALIA
QUEENSLAND DISTRICT REGISTRY
GENERAL DIVISION
QUD 678 of 2012
ON APPEAL FROM THE FEDERAL COURT OF AUSTRALIA
BETWEEN: TRAMANCO PTY LTD (ACN 010 101 872)
AppellantAND: BPW TRANSPEC PTY LTD (ACN 006 645 272)
Respondent
JUDGES:
ALLSOP CJ, GREENWOOD & NICHOLAS JJ
DATE OF ORDER:
13 MARCH 2014
WHERE MADE:
SYDNEY (HEARD IN BRISBANE)
THE COURT ORDERS THAT:
1.The appeal be allowed in part.
2.Declaration 1 and order 2 made by the Court on 9 November 2012 be set aside and in lieu thereof it be:
a)Declared that each of claims 21, 22 and 23 of Australian Patent No 2004264997 is invalid; and
b)Ordered that each of claims 21, 22 and 23 of Australian Patent No 2004264997 be revoked; and
c)Ordered that the application and the cross-claim (in their relevant latest forms) otherwise be dismissed.
3.The appeal be otherwise dismissed.
4.The parties file and serve written submissions on the question of costs, including as to the costs below (up to…
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- Case
- [2014] FCAFC 23
- Decision Date
CaseChat Overview and Summary
The court had to decide several legal issues, including whether the claims met the sufficiency requirement under Australian patent law, whether they were novel, and whether they were obvious in light of prior art. Furthermore, the court had to determine if the claims were infringed by the respondent's actions. The discussion of sufficiency requirements in relation to claims for methods producing specified results was particularly pertinent. The court also needed to consider the interpretation of the phrase "impact loading of the vehicle" within the claims.
The Court found that the claims in question were not sufficiently disclosed as they did not provide enough detail for a person skilled in the art to work the invention. The court held that the claims failed to meet the sufficiency requirement as they did not clearly and concisely describe the invention. The Court also found that claims 21, 22, and 23 were invalid due to lack of novelty and obviousness in light of the prior art. The appeal was allowed in part with respect to the invalidity of claims 21, 22, and 23, and the decision of the primary judge was varied accordingly. The Court set aside the previous declarations and orders and instead declared that the aforementioned claims were invalid and revoked them. The appeal was dismissed in all other respects. The Court ordered that the parties file and serve written submissions on the question of costs within the specified timeframes.
Orders
Orders of the court
1. The appeal be allowed in part.
2. Declaration 1 and order 2 made by the Court on 9 November 2012 be set aside and in lieu thereof it be:
a) Declared that each of claims 21, 22 and 23 of Australian Patent No 2004264997 is invalid; and
b) Ordered that each of claims 21, 22 and 23 of Australian Patent No 2004264997 be revoked; and
c) Ordered that the application and the cross-claim (in their relevant latest forms) otherwise be dismissed.
3. The appeal be otherwise dismissed.
4. The parties file and serve written submissions on the question of costs, including as to the costs below (up to 5 pages in length) within 7 days and any written submissions in reply (up to 2 pages in length) within 14 days.
Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.
Background
Background to the litigation
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Evidence
Evidence Before The Court
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Decision
Reasons for decision
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Ratio Decidendi
Legal Principle Established
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