Boehringer Ingelheim Vetmedica GMBH v. The Controller of Patents

Delhi High Court · 02 Dec 2024 · 2024:DHC:9453
Amit Bansal
C.A.(COMM.IPD-PAT) 225/2022
2024:DHC:9453
intellectual_property appeal_allowed Significant

AI Summary

The Delhi High Court set aside the Controller’s rejection of a patent application for lack of inventive step and remanded the matter for fresh, reasoned consideration addressing the applicant’s submissions.

Full Text
Translation output
C.A.(COMM.IPD-PAT) 225/2022 HIGH COURT OF DELHI
Date of Decision: 2nd December, 2024 C.A.(COMM.IPD-PAT) 225/2022
BOEHRINGER INGELHEIM VETMEDICA GMBH .....Appellant
Through: Mr. Ankush Verma, Mr. Debashish Banerjee, Ms. Vaishali Joshi, Mr. Pankaj Soni, Mr. Vineet Rohilla, Mr. Rohit Rangi and Mr. Tanveer Malhotra, Advs.
VERSUS
THE CONTROLLER OF PATENTS .....Respondent
Through: Mr. Siddhartha Shankar Ray, CGSC
WITH
Mr. Shubham Sharma, Advs.
CORAM:
HON'BLE MR. JUSTICE AMIT BANSAL AMIT BANSAL, J. (Oral)
JUDGMENT

1. The present appeal has been filed under Section 117A of the Patents Act, 1970 (hereinafter the ‘Patents Act’) and is directed against impugned order dated 29th March, 2022 passed by the Assistant Controller of Patents & Designs (hereinafter the ‘Controller’), whereby the Indian Patent Application No. 3157/DELNP/2012 titled “Containers for Compositions Comprising Meloxicam” (hereinafter the ‘subject patent application’) has been refused under Section 15 of the Patents Act.

BRIEF FACTS

2. Brief facts necessary for deciding the present appeal are set out below:

2.1. The appellant, Boehringer Ingelheim Vetmedica GMBH, had filed the subject patent application relating to containers for storage, dispensing and preservation of compositions containing meloxicam on 12th April, 2012 at the Patent Office, New Delhi.

2.2. A request for examination was filed on 12th August, 2013 by the appellant under Section 11B of the Patents Act.

2.3. Subsequently, the subject patent application was examined by the Controller and a First Examination Report (hereinafter, ‘FER’) was issued on 14th January, 2019. The FER essentially contained objections, inter alia, that the claims of the subject patent application were not patentable in terms of Section 2(1)(j) and Section 2(1)(ja) of the Patents Act.

2.4. A detailed response was filed on behalf of the appellant to the aforesaid FER on 17th May, 2019 along with a set of amended claims addressing the objections raised in the FER.

2.5. On 28th October, 2021, a hearing notice was issued by the Controller fixing the date of hearing for 24th November, 2021, wherein once again, objections were taken with regard to lack of novelty and lack of inventive steps in view of the cited prior art documents.

2.6. At the oral hearing, the appellant made submissions denying the Controller’s objections with regard to novelty and inventive steps, especially in light of the cited prior art documents.

2.7. In terms of Rule 28 (7) of the Patent Rules, 2003, the appellant had filed written submission along with further set of amended claims, in respect of the objections raised in the hearing notice on 9th December, 2021.

2.8. In compliance with the requirements under Section 8(1) of the Patents Act, the appellant filed the latest Form 3 update before the Patent Office on 23rd March, 2022.

3. On 29th March, 2022, the impugned order was passed by the Controller rejecting the subject patent application filed by the appellant on the grounds of lack of novelty under Section 2(1)(j) as well as lack of inventive steps under Section 2(1)(ja) of the Patents Act, in view of the cited prior art references, WO2008152122A[2] (D[1]) and WO2009049304A[1] (D[2]). The relevant extracts from the impugned order are set out below:

“7. The applicant’s oral submission during the hearing and written submission dated 09/12/2021 in view of the objections cited in hearing notice regarding Novelty and inventive step in the alleged invention has been considered but is not fully persuasive. In this regard document D1: WO2008152122A2 & D2: WO2009049304A1 are cited as prior art. Regarding independent Claim 1, D1 discloses a plastic container containing a pharmaceutical composition comprising benzoic acid or a derivative or a pharmaceutically acceptable salt thereof and a COX- inhibitor of the oxicam-type or a pharmaceutical acceptable salt thereof, characterised in that the container material is selected from one or more members of the group consisting of a homopolymer of polypropylene (PP), a copolymer of polypropylene (PP), a homopolymer of polyethylene terephthalate (PET) and a co- polymer of polyethylene terephthalate (PET), and optionally one or more non- polymeric components (claims 1, 3, page 6-7). Regarding dependent Claims 2-9, in combination with the features of Claim 1, to which they refer do not contain any new additional features in view of D1. Similarly D2 also discloses the same subject matter at paragraphs 8, 9, 36, 43, 47, figure 1. Inventive step: Claims 1-15 lack inventive step under section 2(1)(j)(a) of the Indian Patents Act 1970, in the light of the document D1 and D2 cited above. From the teachings of D1 and D2 it is obvious to a person skilled in the art to arrive at the subject matter of claims 1-9. In the oral arguments during hearing and written submission thereafter dated 09/12/2021, the applicant states that D1 does not discloses preservatives, the applicant however fails to mention the inventive concept of adding the preservatives in the material. It is common knowledge to add benzoic acid and

preservative salts in plastics. Further applicant requests that the volume of containers mentioned in D[2] are smaller, however changing the volume size again does not constitutes to inventive step. The applicant fails to demonstrate as to what are the specific components in the claimed invention that corresponds to the inventiveness of the idea over the cited prior art. Hence the applicant’s arguments are not persuasive as all the features are disclosed in document D1-D[2] as explained above or are the common general knowledge in field and a skilled person in the art can arrive to the subject matter. Thus the subject matter of claims is not inventive as anticipated by document D1-D[2].”

SUBMISSIONS BY THE PARTIES

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4. Counsel appearing on behalf of the appellant submits that the aforesaid extracts from the impugned order are in substance, a reproduction of the objections raised in the hearing notice issued to the appellant. It is further submitted that detailed written submissions were made on behalf of the appellant in response to the FER as well as the hearing notice, wherein the subject invention has been distinguished from the prior arts cited by the Controller. However, the Controller has passed the impugned order without dealing with the submissions made on behalf of the appellant. Reliance in this regard is placed on the judgments passed by this Court, Agriboard International LLC v. Deputy Controller of Patents and Designs, 2022 SCC OnLine Del 940 and F.Hoffmann-La Roche Ltd. & Anr v. Cipla Ltd., 2015 SCC OnLine Del 13619.

5. Per contra, counsel appearing on behalf of the respondent submits that the appellant has failed to provide any justification or grounds for distinguishing the subject invention from the prevailing prior arts.

ANALYSIS AND FINDINGS

6. I have heard the learned counsel for the parties and examined the records of the case.

7. At this stage, reference may be made to the judgment of a Coordinate Bench of this Court in Agriboard International (supra). The relevant observations are set out below:

“23. The said reasoning has been reiterated by the Supreme Court in Manohar v. State of Maharashtra & Ors. AIR 2013 SC 681 wherein it has been categorically observed that application of mind and recording of reasoned decision are the basic elements of natural justice. There can be no doubt that scrupulous adherence to these principles would be required while rejecting patent applications. 24. In the opinion of this Court, while rejecting an invention for lack of inventive step, the Controller has to consider three elements-  the invention disclosed in the prior art,  the invention disclosed in the application under consideration, and  the manner in which subject invention would be obvious to a person skilled in the art. 25. Without a discussion on these three elements, arriving at a bare conclusion that the subject invention is lacking inventive step would not be permissible, unless it is a case where the same is absolutely clear. Section 2(1(ja) of the Act defines „inventive step‟ as under: (ja) “inventive step” means a feature of an invention that involves technical advance as compared to the existing knowledge or having economic significance or both and that makes the invention not obvious to a person skilled in the art. 26. Thus, the Controller has to analyse as to what is the existing knowledge and how the person skilled in the art would move from the existing knowledge to the subject invention, captured in the application under consideration. Without such an analysis, the rejection of the patent application under Section 2(1)(ja) of the Act would be contrary to the provision itself. The remaining prior arts which are cited by ld. Counsel having not been considered in the impugned order, the Court does not wish to render any opinion in this regard.” [emphasis supplied]

The judgment in Agriboard International (supra) has been consistently followed in several other cases. [reference may be made to C.A.(COMM- IPD-PAT) 8/2022 titled Auckland Uniservices Limited v. Assistant Controller of Patents and Designs, N.V. Satheesh Madhav and Anr. v. Deputy Controller of Patents and Designs, 2022 SCC OnLine Del 4568]

8. In the present case, the appellant had filed detailed written submissions post hearing on 9th December, 2021, wherein the appellant had sought to distinguish the prior arts D[1] and D[2] from the subject inventions. The relevant extracts from the said written submissions distinguishing subject patent application from the D[1] and D[2] individually and in combination which are not addressed in the impugned order are reproduced below: Differentiation from D[1]: “Document D[1] discloses multi-layered plastic polymeric containers that are useful for the storage of sterile or non-sterile pharmaceutical compositions, such containers comprising at least three polymeric layers, a gas barrier layer and an adhesive layer. The complex containers of D[1] are therefore very different from the simple containers of the present invention consisting of polypropylene or PET homopolymers and/or copolymers.” Differentiation from D[2]: “D[2] does not teach or suggest the solution of the present invention, which is selection of a specific container wall material for increasing the shelf life. In contrast, the solution of D[2] for the stability problem is a special arrangement of container compartments. In this regard, D[2] suggests a container with a storing cavity and a dispensing end in defined size ratios (Fig. 1, claim 1, working examples) D[2] does not suggest that specific plastic container materials could affect absorption of certain substances. Even further, it is not disclosed that PP or PET could be advantageous in this regard, let alone for preventing absorption of sodium benzoate. In section [0047] of D[2], it is only noted in general that the container material should not “react” with the formulation. Overall, D[2] is not only silent about the solution of the present invention, but clearly teaches away from it. It is emphasised again that the relevant question is not whether the skilled person could have taken into account D[2], and thus a PP or PET container material disclosed therein. Instead, the relevant question is whether he would have done so, i.e. whether he had an incentive to do so. Obviously, D[2] does not provide an incentive to solve the problem of enhanced shelf-life by using a PP or PET container material instead of PE or glass as disclosed.” Differentiation from combined teaching of D[1] and D[2]: “Furthermore, there is also absolutely no disclosure of the advantageous effect according to the present invention: here, a plastic container is used in a predefined volume range, which allows a stable storage of the sodium benzoate containing meloxicam suspension in a predefined volume range by avoiding the mandatory presence of stabilising additives and by avoiding a significant loss of sodium benzoate during such storage.” [emphasis supplied]

9. Despite the above submissions seeking to distinguish the prior arts from the subject invention, the impugned order has been passed without going into the explanation/justification offered on behalf of the appellant with regard to the prior arts. The impugned order, in a blanket manner, concludes that the arguments made by the appellant in written submissions or on the date of oral hearing are “not fully persuasive” without giving any justification for the same.

10. As noted above, the impugned order has substantially reproduced the contents of the hearing notice. In the judgment passed in Huhtamaki OYJ and Anr. v. Controller of Patents, 2023 SCC OnLine Del 3272, this Court had expressed concerns about the tendency in the Office of Controller of Patents and Designs to reject patent applications by relying on the objections issued to the applicant without considering the submissions of the applicant filed in response thereto.

11. In light of the foregoing analysis, the impugned order dated 29th March, 2022 rejecting the subject patent application of the appellant is set aside and the matter is remanded back to the Patent Office for fresh consideration. The fresh consideration would take into account the material already on record and more particularly, the submissions filed on behalf of the appellant with regard to the cited prior arts.

12. The Patent Office shall endeavour to pass a reasoned order taking into account all the relevant considerations within two months. List before the Controller of Patents on 16th January, 2025.

13. The Registry is directed to supply a copy of the present order to the Office of the Controller General of Patents, Designs & Trademarks of India on the e-mail ID- llc-ipo@gov.in for compliance.

14. The appeal stands disposed of in terms of the above. AMIT BANSAL, J DECEMBER 2, 2024