- Case number
- C.A.(COMM.IPD-PAT) 318/2022
- Court
- Delhi High Court
- Date of judgment
- Judge
- Prathiba M. Singh
- Outcome
- Allowed
Headnote
Section 3(k) objection rejected and the patent directed to proceed to grant, as amended. Drawing on Terrell on the Law of Patents, the Court accepted that two kinds of technical advantage attributable to a computer program suffice: where the program solves a problem within the computer itself, and where its beneficial consequences feed into other devices. A technical innovation, whether within or outside the computer, will normally suffice. Here cache management unifying and updating libraries, metadata-only library files for efficient transfer and dynamic media synchronisation produced effects both within the computer, in optimised storage and retrieval, and beyond it, in the functioning of mobile devices and the accessibility of media. No objection to novelty or inventive step had been taken by the Patent Office, but the Court examined the European prior art for completeness and found that it did disclose selecting media files for transfer on criteria such as popularity weighting and recency of access. Rather than refuse or remand, the Court directed the claims be recharacterised so that the confidence-level feature stands as the prior art over which automatic selection and updating by a cache manager are the novel advance, and set out the rewritten claim in the judgment.
Headnote by BRB Legal, written from the judgment: a summary for reference, not legal advice. Read the judgment itself before relying on it.