European Patent Office

T 0438/19 of 27.06.2023

European Case Law Identifier
ECLI:EP:BA:2023:T043819.20230627
Date of decision
27 June 2023
Case number
T 0438/19
Petition for review of
-
Application number
11830390.8
Language of proceedings
English
Distribution
Published in the EPO's Official Journal (A)
Other decisions for this case
T 0438/19 2025-10-15
Abstracts for this decision
Abstract on EPC2000 Art 054
Application title
SOLAR CELL SEALING MATERIAL, AND SOLAR CELL MODULE
Applicant name
Mitsui Chemicals, Inc.
Mitsui Chemicals ICT Materia, Inc.
Opponent name
Borealis GmbH
Board
3.3.03
Headnote
-
Relevant legal provisions
European Patent Convention Art 100(b)European Patent Convention Art 112(1)(a)European Patent Convention Art 54(2)Rules of procedure of the Boards of Appeal Art 12(4)
Keywords
Document resubmitted with the statement of grounds of appeal - admitted (yes)
Sufficiency of disclosure (yes)
Inventive step
Referral to the Enlarged Board of Appeal
High Court of England and Wales TAKEDA UK LTD v F. HOFFMANN-LA ROCHE AG [2019] EWHC 1911
Catchword
The following questions are referred to the Enlarged Board of
Appeal for decision:
1. Is a product put on the market before the date of filing of a European patent application to be excluded from the state of the art within the meaning of Article 54(2) EPC for the sole reason that its composition or internal structure could not be analysed and reproduced without undue burden by the skilled person before that date?
2. If the answer to question 1 is no, is technical information about said product which was made available to the public before the filing date (e.g. by publication of technical brochure, non-patent or patent literature) state of the art within the meaning of Article 54(2) EPC, irrespective of whether the composition or internal structure of the product could be analysed and reproduced without undue burden by the skilled person before that date?
3. If the answer to question 1 is yes or the answer to question 2 is no, which criteria are to be applied in order to determine whether or not the composition or internal structure of the product could be analysed and reproduced without undue burden within the meaning of opinion G 1/92? In particular, is it required that the composition and internal structure of the product be fully analysable and identically reproducible?

Order

For these reasons it is decided that:

The following questions are referred to the Enlarged Board of

Appeal for decision:

1. Is a product put on the market before the date of filing of a European patent application to be excluded from the state of the art within the meaning of Article 54(2) EPC for the sole reason that its composition or internal structure could not be analysed and reproduced without undue burden by the skilled person before that date?

2. If the answer to question 1 is no, is technical information about said product which was made available to the public before the filing date (e.g. by publication of technical brochure, non-patent or patent literature) state of the art within the meaning of Article 54(2) EPC, irrespective of whether the composition or internal structure of the product could be analysed and reproduced without undue burden by the skilled person before that date?

3. If the answer to question 1 is yes or the answer to question 2 is no, which criteria are to be applied in order to determine whether or not the composition or internal structure of the product could be analysed and reproduced without undue burden within the meaning of opinion G 1/92? In particular, is it required that the composition and internal structure of the product be fully analysable and identically reproducible?