Delhi High Court Emphasizes the Importance of Claim Mapping in Patent Cases
Source:https://www.researchgate.net/figure/Patent-claim-map-introducing-relationships-among-neighbouring-patents_fig1_285968399
On October 9, 2024, the Delhi High Court delivered a significant ruling in the case of Hoffmann-La Roche AG vs. Zydus Lifesciences Limited, emphasizing the critical concept of claim mapping in patent infringement cases, particularly when petitioning for interim injunctions.
Key Points from the Ruling:
1. Definition of Claim Mapping: Claim mapping involves a detailed comparison between the claims outlined in a patent and the allegedly infringing product or process. This step is crucial to establish whether there is actual infringement.
2. Judicial Requirements for Injunctions: Justice Saurabh Banerjee articulated that to secure a temporary injunction, a patent holder must present evidence of not only a prima facie case and the balance of convenience but also successful claim mapping. This means the applicant must show that the infringing product is likely to or has already infringed upon the patent claims.
3. Details of the Case: Roche sought to inhibit Zydus Lifesciences from marketing "Sigrima," which Roche argued was a biosimilar to its patented drug, Pertuzumab (marketed as Perjeta). Roche contended that Zydus's product directly infringed on its patent rights.
4. Court’s Decision: The Court dismissed Roche’s plea, noting that the absence of adequate claim mapping evidence prevented it from granting an interim injunction. The ruling highlighted that merely having a registered patent is insufficient for protection against infringement claims. Roche's patents were still under examination, and granting an injunction without strong evidentiary support would undermine the provisions of the Patents Act of 1970.
5. Significance of the Ruling: This judgment serves as a reminder for patent holders that they must substantiate their claims of infringement with specific evidence connecting their patents to the alleged infringing products. The Court underlined that claim mapping is essential for establishing the viability of patent infringement claims, especially in the context of seeking temporary relief.
Conclusion:
The Delhi High Court's decision underscores the necessity of thorough preparation and understanding in patent infringement cases. It highlights the importance of claim mapping as a pivotal element in demonstrating infringement, setting a precedent for future cases. Companies seeking to enforce their patent rights must ensure that they can clearly articulate how an alleged infringer's product correlates with their patented claims to gain the court's favor in injunction requests. This ruling not only clarifies legal expectations but also reinforces the principle that diligent evidence-gathering is integral to protecting intellectual property rights.
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