Ranbaxy Laboratories Ltd. & Ors v. Warner-Lambert Co. [2005] IEHC 178 (8 June 2005)

Ranbaxy Laboratories Ltd. & Ors v. Warner-Lambert Co. [2005] IEHC 178 (8 June 2005)

Documents comprising representations by the patentee or its agents, whether made to foreign patent offices or internally, are inadmissible for the purpose of construing the Irish patent, as they reflect subjective intentions or interpretations, which are irrelevant to the objective legal construction of the patent claims. The principle of admissions against interest does not apply in this context.

Citation
[2005] IEHC 178
Parties
Plaintiffs: Ranbaxy Laboratories Limited, Ranbaxy Europe Limited and Ranbaxy Ireland Limited; Defendant: Warner-Lambert Company
Jurisdiction
Ireland
Judgment Date
08 June 2005
Procedural Posture
Commercial List / Patent Dispute / Interlocutory Application Regarding Admissibility of Documents for Discovery
Outcome
Application refused
Legal Topics
Patent Construction, Admissibility of Evidence, Discovery, Interpretation of Patent Claims, Statements Against Interest, Foreign Patent Prosecution History
Intellectual Property Law Patent Law Patent Construction Admissibility of Evidence Discovery Interpretation of Patent Claims Statements Against Interest Foreign Patent Prosecution History

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Parties

Ranbaxy Laboratories Limited, Ranbaxy Europe Limited and Ranbaxy Ireland Limited

Plaintiffs

Warner-Lambert Company

Defendant

Procedural Posture

Commercial List / Patent Dispute / Interlocutory Application Regarding Admissibility of Documents for Discovery

Legal Issues

  1. 1 Whether documents evidencing patentee's representations to foreign patent offices and internal memoranda are admissible in evidence for the purpose of construing the Irish patent
  2. 2 Whether such documents are admissible as statements against interest

Ratio Decidendi

Documents comprising representations by the patentee or its agents, whether made to foreign patent offices or internally, are inadmissible for the purpose of construing the Irish patent, as they reflect subjective intentions or interpretations, which are irrelevant to the objective legal construction of the patent claims. The principle of admissions against interest does not apply in this context.

Court Disposition

Application refused

Orders

  • Documents sought by the plaintiffs are inadmissible for the purpose of construing the patent and are not to be discovered on that basis.