Rockwater Ltd v Technip France SA & Anor [2004] EWCA Civ 381 (01 April 2004)

Rockwater Ltd v Technip France SA & Anor [2004] EWCA Civ 381 (01 April 2004)

The Court held that the Toisa Perseus device did not fall within claim 3 of the patent as properly construed, and that the patent was invalid for want of novelty and obviousness. The claims, when interpreted in light of the specification, drawings, and common general knowledge, did not cover Rockwater's device. The technical problems addressed by the patent were longstanding and the alleged inventive step was obvious in light of prior art.

Citation
[2004] EWCA Civ 381
Parties
Claimant/part 20 Defendant: Rockwater Ltd; Defendant/part 20 Claimant: Technip France SA (formerly Coflexip SA); Defendant/part 20 Claimant: Technip Offshore UK Limited (formerly Coflexip Stena Offshore Limited)
Jurisdiction
England and Wales
Judgment Date
01 April 2004
Procedural Posture
Patent Infringement and Revocation / Appeal From Chancery Division (patents Court) to Court of Appeal
Outcome
Appeal dismissed; patent held invalid and not infringed.
Legal Topics
Patent Construction, Patent Validity, Obviousness, Novelty, Infringement, Prior Art
Intellectual Property Patents Patent Construction Patent Validity Obviousness Novelty Infringement Prior Art

Case Brief

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Parties

Rockwater Ltd

Claimant/part 20 Defendant

Technip France SA (formerly Coflexip SA)

Defendant/part 20 Claimant

Technip Offshore UK Limited (formerly Coflexip Stena Offshore Limited)

Defendant/part 20 Claimant

Procedural Posture

Patent Infringement and Revocation / Appeal From Chancery Division (patents Court) to Court of Appeal

Legal Issues

  1. 1 Whether the Toisa Perseus device falls within claim 3 of the patent
  2. 2 Whether the patent is invalid for want of novelty or obviousness
  3. 3 Proper construction of claims 1 and 3 of the patent

Ratio Decidendi

The Court held that the Toisa Perseus device did not fall within claim 3 of the patent as properly construed, and that the patent was invalid for want of novelty and obviousness. The claims, when interpreted in light of the specification, drawings, and common general knowledge, did not cover Rockwater's device. The technical problems addressed by the patent were longstanding and the alleged inventive step was obvious in light of prior art.

Court Disposition

Appeal dismissed; patent held invalid and not infringed.

Orders

  • Patent declared invalid for want of novelty and obviousness.
  • No infringement by Rockwater Ltd.