Slater Steel Industries Ltd. v. Lacal Industries Ltd.

Slater Steel Industries Ltd. v. Lacal Industries Ltd.

The patent was invalid for want of subject-matter because the core idea—locating bundle conductors proximate to the lowermost insulators to improve voltage distribution and reduce corona—was part of the known electrical implications and common general knowledge by 1958 and did not involve the required inventive step beyond routine mechanical design; accordingly the appeal was dismissed and the declaration of invalidity upheld.

Citation
[1972] SCR 29
Parties
Defendant Appellant: Slater Steel Industries Limited; Plaintiff Respondent: Lacal Industries Limited
Court
Supreme Court of Canada
Jurisdiction
Canada
Judgment Date
5 April 1971
Procedural Posture
Patent Appeal / Appeal to Supreme Court of Canada Final Judgment on Validity
Outcome
appeal dismissed
Legal Topics
Patent Validity, Subject Matter, Inventive Step/obviousness, Infringement, Claim Specificity
Source Language
English
Intellectual Property Patent Law Patent Validity Subject Matter Inventive Step/obviousness Infringement Claim Specificity

Case Brief

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Parties

Slater Steel Industries Limited

Defendant Appellant

Lacal Industries Limited

Plaintiff Respondent

Procedural Posture

Patent Appeal / Appeal to Supreme Court of Canada Final Judgment on Validity

Legal Issues

  1. 1 Whether the patent met the statutory subject-matter requirement
  2. 2 Whether the claimed positioning of conductors involved an inventive step or was obvious from prior art/common general knowledge
  3. 3 Whether prior use/knowledge (by 1958) anticipated the claimed invention

Ratio Decidendi

The patent was invalid for want of subject-matter because the core idea—locating bundle conductors proximate to the lowermost insulators to improve voltage distribution and reduce corona—was part of the known electrical implications and common general knowledge by 1958 and did not involve the required inventive step beyond routine mechanical design; accordingly the appeal was dismissed and the declaration of invalidity upheld.

Court Disposition

appeal dismissed

Orders

  • Appeal dismissed
  • Patent declared invalid and void