Canadian Intellectual Property Bulletin


Volume 12 - November, 2001

This newsletter is not intended to constitute a legal opinion on any of the issues discussed. Readers should seek professional legal advice on issues of concern to them - we would be pleased to elaborate on any of the articles herein and discuss how it might apply to specific problems. Contact us for more information.

Changes In Patent Office Practice Respecting Entity Status And Fees: Dutch Industries Ltd. V. Canada (Commissioner Of Patents), [2001] F.C.J. No. 1250 (F.C.T.D.)

The Canadian Intellectual Property Office (CIPO) has recently changed its earlier practice of accepting corrective payments from patentees and applicants (hereinafter "Patentees") who failed to pay the prescribed amount of fees by the appropriate deadlines. A recent notice from IPO advises, "CIPO will not accept any corrective payments which are submitted after a due date, unless the appropriate actions are taken as required by legislation .". In certain instances in the past, when a fee was paid in an incorrect amount, and when a Patentee later sought to rectify the error by offering corrective payment, CIPO accepted such payment and even went so far as to adjust its records to indicate that the fee had been appropriately paid. Apparently, in certain instances, this occurred when all deadlines, and extensions of deadlines had been exhausted. Although the issue may appear technical and trite, there are potentially significant ramifications in that the interests of Patentees could be significantly and retroactively prejudiced. Furthermore, protection from such prejudice requires the diligence of Patentees as well as that of their patent agents to ensure that the proper fees are paid at all times.

The Canadian Intellectual Property Office was prompted to adopt its current (changed) position by the decision of the Federal Court of Canada in Dutch Industries Ltd. v. Canada (Commissioner of Patents) (2001), FCT 879; [2001] F.C.J. No. 1250 (FCTD). That case involved CIPO's acceptance of corrective payments for fees assessed based on the declared entity status of a Patentee.

Patentees are recognized by CIPO as being either large or small entities. The principle use of that distinction is to provide a benefit to Patentees who are small entities. CIPO assesses lower fees to small entities for various actions and services. Authority for such discrimination is found in the Patent Act and the Patent Rules. However, CIPO does nothing to determine or verify the entity status any Patentee. Rather, the legislation puts the onus on each Patentee to correctly identify its entity status and thereby verify its entitlement or disentitlement to the benefits of small entity status.

The Patent Act defines a small entity as follows:

"small entity" in respect of an invention, means an entity that employs 50 or fewer employees or that is a university, but does not include an entity that

(a) has transferred or licensed, or is under a contractual or other legal obligation to transfer or license, any right in the invention to an entity, other than a university, that employs more than 50 employees, or

(b) has transferred or licensed, or is under a contractual or other legal obligation to transfer or license, any right in the invention to an entity that employs 50 or fewer employees or that is a university, and has knowledge of any subsequent transfer or license of, or of any subsisting contractual or other legal obligation to transfer or license, any right in the invention to an entity, other than a university, that employs more than 50 employees;

This definition encompasses individual inventors and small entities such as corporations and partnerships that employ 50 or fewer employees. Large entities are those that do not fit within the definition of a small entity.

The Dutch Industries Ltd. case dealt with the particular circumstances following:

1. A small entity ("B") acquired rights in an invention and filed a patent application.

2. B properly declared itself a small entity.

3. B then assigned its interests in the invention to a large entity ("F").

4. The application for a patent was granted by the Canadian Intellectual Property Office.

5. After the assignment, B paid fees to CIPO to maintain in good standing the application (during the pendancy period) and, later, the issued patent. The fees paid were those assessed on a small entity.

6. After various maintenance fees were finally due (after the expiry of all legislated reinstatement periods), B realized that, because of the assignment of its rights in the invention to F, the fees that should have been paid were those assessed on a large entity.

7. B sought to correct its error by remitting to CIPO the difference between the amount paid (small entity) and the amount due (large entity).

8. CIPO accepted the corrective payment and amended its records to show that large entity fees were due and had been paid.

9. B and F sought to assert their patent rights against an alleged infringer ("D").

10. D defended itself by seeking judicial review of the decision of the Commissioner of Patents to accept corrective payment. D argued that any rights that B and/or F may have had in the invention irrevocably lapsed with B's failure to pay the appropriate fees within the times established by the Act and the Rules.

11. B and F argued that it was within the scope of the Commissioner's discretion to accept corrective payment.

12. Although the Com missioner chose not to participate at the hearing, evidence was presented indicating that it was a regular practice of CIPO to, in similar circumstances, accept corrective payment and amend its records to indicate compliance with the Act and Rules.

The Court ruled in favor of Dutch and set aside the decision of the Commissioner to accept corrective payment. Madam Justice Dawson noted that the statutory regimen establishes a mandatory requirement to pay the prescribed fees and, upon failure to pay the specified fees before the expiration of the prescribed time periods, a mandatory consequence of deemed abandonment. Furthermore, she held that, while the Rules give broad discretion and authority to the Commissioner to extend the time for doing anything, they also withhold the exercise of such discretion and authority to extend the time both for paying maintenance fees and for reinstating an application deemed abandoned for failure to pay maintenance fees. Therefore, Dawson, J. concluded that the Commissioner (CIPO) lacks jurisdiction to accept corrective payment when a Patentee fails to meet the legislated requirements respecting the payment of fees.

Notice has been given of an intention to appeal the decision. However, in the event that the Court's decision stands, any Patentee that is in arrears for fees consequent to a past error in the determination of its entity status or failure to advise of a change in status (small to large) would find its rights to be lapsed from the date of such arrears. Such lapsing of rights, consequent to deemed abandonment of a patent or application, would be not be reversible once all reinstatement periods expired. The decision would be applicable to issued patents and applications. It the latter case, no valid patent could issue from a lapsed application. All Patentees should carefully review their entity status and put in place appropriate systems to ensure regular review. The definition of a small entity contained in the Patent Act (reproduced above) can give rise to confusion with regard to the determination of employment. For example, the attribution of part time and temporary employees must be considered and the status, within firms of individuals who may be employees, independent contractors, directors, shareholders or others must be evaluated. Also, firms that have grown or that have assigned or licensed any right in their invention to another entity may be required to change their recorded status. Should you require assistance in reviewing your portfolio for compliance with these new rules, please do not hesitate to contact us.

Monsanto V. Schmeiser—Update

Monsanto Canada and its U.S. parent company, Monsanto Company, were successful in their patent infringement suit against Percy Schmeiser, a Saskatchewan farmer who was found to have grown patented Round-Up® resistant canola on 1100 acres of land without a license. Schmeiser has also sued Monsanto in the Court of Queen’s Bench in Saska-toon claiming damages for contamination of his crops, defamation, trespass and conversion of his property. Monsanto filed a Statement of Defence on October 4, 1999, but the public record does not indicate whether any other steps have been taken to pursue the matter. It has been reported that Monsanto has, since the decision, begun pursuing other farmers for similar infringement. There have been reports in the press of a farmer at Birsay, Saskatchewan who com-plained of Round-Up® resistant canola growing in his field when he had not planted any of this type of canola. According to the report, Monsanto had sent people into his field to pick the offending canola by hand. While the Schmeiser decision was in Monsanto’s favour, they were not successful in obtaining punitive damages against Mr. Schmeiser. Monsanto originally claimed both profits from growing the infringing canola for the parent U.S. company in the amount of $105,000, and damages for the Canadian company in the amount of $15,450, being the established royalty rate of $15.00 per acre on his 1,030 acres of infringing canola. The Court did not accept that both remedies were available, and ordered that Monsanto was entitled to profits in an amount the parties agreed to. If no agreement was reached, the award would be to Monsanto Canada for $15 per acre. The parties agreed that the profits were $19,000.00 or $18.50 per acre on his 1,030 acres of infringing canola. The court also ordered delivery up of any crop still in Mr. Schmeiser’s possession however it is likely that all that crop had by then been sold. In the end, Mr. Schmeiser paid $3.50 per acre more than he would have paid for a license from Monsanto. Given that approximately half of the canola grown in western Canada is patented Round-Up® resistant canola, and given that it seems generally accepted that the patented canola will cross-pollinate with other canola or even other plants, it will be interesting to see in the future what Monsanto’s reaction is if the problem becomes much more widespread, which seems highly likely.

United States: Festo Deci Sion Limits Doctrine Of Equivalents

In U.S. patent law, the doctrine of equivalents has in the past allowed for a finding of patent infringement when patent claims were not literally infringed, but instead an "equivalent" was substituted for an element in the claim. A basic illustrative example would be where the claimed element was a screw and a competitor’s product used a bolt or rivet, it would still infringe the claim unless there was a functional difference between the substituted equivalent and the originally used item. In recent years, the application of the doctrine of equivalents has been limited by arguments and amendments made by the patentee during prosecution of the patent (prosecution history estoppel). Where an element of a patent claim was amended during prosecution for reasons of patentability, for example to avoid prior art, then the doctrine of equivalents was not applicable to that element. The court then looked at the amendment that was made during prosecution and decided whether it was made to avoid prior art and whether the doctrine of equivalents could be applied to that element or not. For example, if the applicant for a

patent specifically argued that they used a screw for a particular functional purpose (referencing the example above), in order to distinguish their invention from something which used a different fastener such as a bolt or a rivet, they cannot then turn around in enforcement of their patent and argue that a bolt or rivet is covered within the scope of their patent claim as an equivalent fastener.

In Festo Corp. v. Schoketsu Kinzoku Kogyo Kabushiki Co., November 29, 2000, a divided Court of Appeals for the Federal Circuit in the United States (the body that handles appeals in patent cases) effectively extended prosecution history estoppel by denying the application of the doctrine of equivalents in any case where a claim element was amended for any reason whatsoever. Many articles have been published which claim that this means the death of the doctrine of equivalents in the United States. With over 1 million patents in effect in the United States at this time, almost all of those patents were amended to some extent during prosecution, very often for reasons other than to avoid prior art, such as to more clearly define the invention. Patent agents routinely amended claims where the Examiner requested clarification, regardless of whether the agent felt the Examiner was justified. It was just easier, and in most cases made no substantive change in the claim. What the Festo decision appears to do is to deny the application of the doctrine of equivalents to the majority of patent claims that now exist.

There are many arguments in favor of the Festo decision, the main one being that it provides certainty respecting what is protected. The doctrine of equivalents has always caused considerable uncertainty regarding the scope of a claim and the Festo decision essentially removes much of that uncertainty. Arguments against the Festo decision are of course that it drastically reduces the value of a vast number of patents, and gives free rein to competitive products with only insignificant differences. The United States Supreme Court, in June of 2001, agreed to hear an appeal from the case, which will likely be heard this coming winter.

In Canada, in contrast, the prosecution history of a patent application is not admissible in an infringement action to determine the extent or construction of the patent claims. The Court interprets the patent claims using a "purposive construction" as was recently affirmed by the Supreme Court of Canada in the Freeworld Trust and Whirpool cases. Any amendments made by an applicant during prosecution are totally irrelevant. It is only the final language of the claims construed, if necessary, in light of the disclosure that governs the protection afforded by the patent.

Since most Canadian patent applicants wish to protect their inventions in the U.S. market as well as Canada, or even instead of Canada, the scope of protection afforded by the same patent can differ considerably in each country. In view of the fact that prosecution estoppel has been known for some time to limit the doctrine of equivalents where prior art is concerned, agents prosecuting patent applications in recent years have generally avoided making amendments unless absolutely necessary. It remains to be seen where the Supreme Court comes down on this issue.

Our New Look

Over the summer we have completed the conversion to our new web site and adoption of our new corporate identity. We hope you like it as much as we do! We welcome you to check out our new web site. We are particularly excited about our upcoming client area, where clients will be able to access docket and status information and other particulars regarding matters we are handling on their behalf, in a secure environment. This functionality should be available by the end of the year—please let us have your comments on the content of our web site so that we can continue to improve its value to you as an information source.

United States: Patent Applications To Be Laid Open To The Public

Prior to enactment of the American Inventors’ Protection Act of 1999, a new patent application filed in the United States was maintained secret until it was issued. If the Patent Office refused to issue a patent, the contents of the patent application were never made public. This essentially allowed an inventor to maintain his invention in confidence and secrecy until he was assured that a patent would be issued, and if the patent was refused then he could continue to maintain it’s secrecy. The recent changes to legislation in the U.S. now require that any patent that will be filed in the United States and in other countries will be laid open 18 months after the filing date, as are patent applications in substantially all of the rest of the world. The change was made in the U.S. to bring practice there into line with the practice in other countries. A significant exception to the publication rule is where the applicant for the patent states that there will be no applications filed in any other country. In that case, the application will remain secret until it is issued. One practical effect of this on our clients has been with respect to formal drawings. Previously, patent applications were often filed with sketches or informal drawings. Formal drawings were only required in the United States after the patent was allowed and prior to issue. The Patent Office will now requires formal drawings of "publication quality" prior to laying open the application to the public. Practically speaking, these new rules require that formal drawings be submitted either with the application or within a couple of months thereafter. Filing the drawings after the application incurs extra expense, and so we are now advising clients that the formal drawings should be prepared at the time of filing of the U.S. patent application to minimize delay and extra expense.

Cyber- Squatting In Canada

Cyber squatting activities in Canada or by Canadian parties, both in the .ca domain as well as other top level domains, has to date in Canadian courts been dealt with on a case by case basis. Several recent court decisions illustrate the present state of the law in Canada with respect to cyber squatting. The handling of cyber squatting situations within the .ca domain will be simplified to some extent once a dispute resolution policy is adopted by the Canadian Internet Registration Authority.

Canadian judicial treatment of cyber squatting cases:

Trademark owners or domain name applications seeking dispute resolution services within the .ca TLD are limited to taking court action at this time, since the ADR policy of the .ca TLD has not yet been implemented. There have been other judicial treatments of cases in Canada involving Canadian parties within the .com domain for example, and others.

The decision of the Saskatchewan Court of Queen’s Bench in the case of Saskatoon Star Phoenix Group Inc. v. Noton (12 C.P.R. (4 th ) 4) deals with a cyber squatter in the .com domain. The Saskatoon Star Phoenix is a city newspaper. It came to their attention that the defendant was holding domain names including saskatoonstarphoenix.com, thestarphoenix.com and starphoenix.com, and offering them for sale, and also had a web site up on at least one of these domain names which basically mirrored the content of the plaintiff’s actual website but replaced the banner advertising of the plaintiff’s with that of the defendant. The plaintiff sought an interlocutory injunction, which the Court granted and the defendant obeyed. The defendant did not appear, however, to present any defense to the action. His only defense, noted by the judge in his decision and learned through newspaper articles related to the defendant and the case, was that the defendant thought that trafficking in domain names was a legitimate commercial activity. The judge indicates that prior to the WIPO decision in favor of Celine Dion, "there was very little, if any, precedent to guide would-be entrepreneurs of domain names prior to this and other recent decisions." The Court was satisfied on the basis of the plaintiff’s material that the defendant was passing off as the plaintiff and that the elements of that tort were all established. The domain names in question were ordered transferred. Of particular note from this decision are the indication by the Court that in a case where several such decisions were made against the same defendant, punitive damages may be appropriate. The Plaintiff had requested their costs on a solicitor-client basis, and the Court held that party-party costs would not be sufficient in this case since the defendant had taken no action to investigate his legal position following receipt of a cease and desist letter from the plaintiff, had not defended the proceedings, "and indeed it is not obvious that a defense was available". In awarding costs in the amount of $7,500, the judge held it was essential to teach the defendant the lesson that he could not recklessly go about causing people to incur substantial legal expense to get him to cease his illegal activities.

In Itravel2000.com Inc. v. Fagan (11 C.P.R. (4 th ) 164), the Ontario Superior Court dealt with another domain name ownership conflict. The plaintiff, a Canadian company, operated a travel business at itravel2000.com. The defendant registered the domain name itravel.ca with CIRA. Both plaintiff and defendant had Canadian trademark applications pending claiming rights in the mark for use on online travel services, amongst others, with the plaintiff claiming an earlier date of first use. The Court’s decision indicates that the defendant was primarily engaged in the windshield repair business, and did not do any travel-related business, yet he claimed a date of first use of March 9, 1999. On this basis it is submitted that the validity of the trademark application of the defendant is questionable at best. The application was only filed around the time of receiving a cease and desist letter or other communication from counsel for the plaintiffs. The plaintiff sought interim and final relief prohibiting the defendant from selling or using the itravel.ca domain name, or alternatively ordering the transfer of that domain name to the plaintiff. The Court issued an injunction prohibiting the defendant from using or transferring the domain name pending final resolution of the matter.

In another cyber squatting case, the cyber squatter has been enjoined from selling the domain name in question pending the outcome of the action. The Alberta Court of Queen’s Bench issued this injunctive relief in Innersense International Inc. v. Manegre (7 C.P.R. (4 th ) 107). The facts of that case involved a consultant who developed the innersense.com website and domain name for the plaintiff and subsequently resigned from her position. The plaintiff received no notice from NSI regarding the upcoming renewal deadline for the domain name (which notice was presumably directed to the defendant), and the defendant’s brother registered the domain name when it expired for non-renewal and proceeded to offer it back to the plaintiff for sale for $20,000, as well as to advertise it elsewhere for sale.

Dispute resolution in the .ca domain:

Since transfer of control of the .ca domain to the Canadian Internet Registration Authority (CIRA) late last year, CIRA has not yet implemented a dispute resolution policy. There is a Canadian Dispute Resolution Policy (CDRP) which has been drafted and circulated for public comment, loosely modeled on the ICANN UDRP. Expressions of interest have been received from potential ADR service providers, and these are now under consideration along with the issue of the number of service providers which should be chosen. The CIRA has recently completed the election of their first Board of Directors and indicates that the CDRP should be finalized and implemented by the end of this year. The draft policy and status documentation is available on the CIRA website, cira.ca. Pending completion of the CIRA dispute resolution policy, trademark owners with Canadian cyber squatting issues will need to continue to seek remedies in the courts.

Joining Our Firm

Furman & Kallio are pleased to welcome Dr. Tom Roberts as an associate to the firm. Tom joins us to practice in the biotechnology area and his practice involves Canadian and foreign patent prosecution (biotechnology, biologics, chemical); regulatory compliance, technology licensing, due diligence and related portfolio matters.

Prior to joining the legal profession Tom was a virologist/molecular biologist involved in biotechnology research in industrial and quasi-industrial settings and, later, in the man-agement

of intellectual and industrial property with a corporation engaged in the devel-opment of advanced electronics technologies. He was engaged in the general practice of law for about three years before joining Furman & Kallio in May 2001. Tom’s recent accomplishments include working with the University of Saskatchewan in the establish-ment of their Virtual College of Biotechnology, as well as publication of Life Forms as Patentable Subject Matter: Is a Divergence in Canadian and U.S. Laws Warranted? Occasional Paper No. 7, Centre for Studies in Agriculture, Law and the Environment, Saskatoon, Saskatchewan.

Tom’s research background and credentials will assist our clients in the development and enforcement of biotechnology-related intellectual properties in Canada and abroad.

Trademark Registration Basics—Canada:

The following are some of the basic information required for domestic or foreign trademark practitioners to have a basic understanding of Canadian trademark registration practice.

Application Basis: A trademark application in Canada can be filed claiming prior use in Canada (provided such prior use is substantial, the prior user might also exercise common law trademark rights in canceling subsequent trademarks and suing for infringement, even in the absence of registration, although the cost and difficulty of such an action is more difficult than if a trademark registration is in place). Other bases of a trademark application in Canada can include intent to use the mark in Canada, making a trademark well known in Canada, or filing an application in a home country and using the trademark in a Paris Convention country. Also, an existing or pending home registration can serve as a basis for a Canadian application.

Approximate Pendency Time: It is our current experience that trademark applications remain pending for approximately 18 to 24 months from start to finish, in cases lacking protracted examination or opposition difficulties.

Assignments of Trademark Applications or Registrations: It is possible to assign Canadian trademark applications and registrations. Assignments can be recorded in the Canadian Intellectual Property Office and it is advisable to do so.

Claiming Priority to a Foreign Application or Registration: It is possible to claim Paris Convention priority in Canada, within the six month period following the filing of the home application.

Classification of Goods and Services: The International Classification of Goods and Services does not apply in Canada. As well, all different types of wares and services can be included in one application – separate applications for different classifications of wares and services are not necessary for any legal reason, although this type of an approach can still be taken if there is a tactical preference to do so.

Intent to Use (ITU) Applications: An applicant filing a trademark application on the basis of an intent to use the mark in commerce in Canada has up to three years from the date of filing of the Canadian application to declare the mark in use on the wares and services contained in the application.

Licensing Obligations: It is possible and permissible to license Canadian trademark applications or registrations. Licenses do not have to be recorded, but the licensor does need to maintain a degree of control over the character or quality of the goods or services. We are pleased to provide opinions as to the sufficiency of various licensing provisions, should you so require.

Searching in Advance of Filing: Various levels of searching can be undertaken in advance of filing a Canadian application. If you wish to conduct a simple trademark search, you can access the entire Canadian Trademarks Database free of charge via our Web site, www.furman-kallio.com. For more complex searches or opinions, we are pleased to advise our clients regarding same.

Term of Registration: A Canadian trademark registration lasts for 15 years from the date of registration. The trademark is then renewable in similar 15 year periods thereafter.

What is Registrable: A word mark or design mark, or symbol or shape of the wares or their packaging that is distinctive of the wares or services of the applicant are in most cases protectable. This is subject to the requirement that the mark be distinctive, and not be primarily merely the surname of an individual who is living or has died within the preceding 30 years, is either clearly descriptive or deceptively misdescriptive in the English or French languages of the character or quality of the wares or services, is the name in any language of the wares or services in connection with which it is proposed to be used, is confusing with a registered trademark, or is a mark which is prohibited by Section 9 of the Trademarks Act, or a potential geographical indication.

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