MétaCan
Menu
Back to cohort
Record W2064330952 · doi:10.1093/jiplp/jpu225

UK claim construction: return of the Protocol questions and file wrapper estoppel

2014· article· en· W2064330952 on OpenAlex
Robert D. Cox, Siân Spink

Why this work is in the frame

A frame that forgets how it found something cannot be audited. These are the routes that admitted this work.

aboutThe title or abstract carries a Canadian signal from the geographic lexicon.
no affNo Canadian affiliation: this work is invisible to an affiliation-only frame.
No Canadian affiliation. An affiliation-only frame, the usual design, would never have seen this work. It is one of the works that make the case for inverting the frame.

Bibliographic record

VenueJournal of Intellectual Property Law & Practice · 2014
Typearticle
Languageen
FieldBusiness, Management and Accounting
TopicIntellectual Property and Patents
Canadian institutionsnot available
Fundersnot available
KeywordsEstoppelComputer scienceProtocol (science)World Wide WebLibrary scienceInformation retrievalPolitical scienceLawDoctrineMedicine

Abstract

fetched live from OpenAlex

The law of patent construction in the UK has been largely settled since the 2004 House of Lords' decision in Kirin-Amgen which, in confirming purposive construction as the correct approach, ruled out any US-style doctrine of equivalence. It also doubted the utility of the Protocol Questions, despite their regular application by the UK courts and the adoption of similar questions in other EU jurisdictions. The law on file wrapper estoppel, the use of a patent's prosecution history to estop the patentee from arguing a different construction during litigation, has been settled for even longer. The UK courts have felt strongly that it should not be necessary to read the prosecution history in order to determine a patent's scope. Germany and Canada concur with the UK's approach, however, the US courts take the opposite stance with file wrapper estoppel providing a counterbalance to its doctrine of equivalents. Mr Justice Arnold's judgment in Actavis v Eli Lilly has reopened both these issues. Arnold J not only applied the previously defunct Protocol Questions in construing Eli Lilly's Alimta patent but then used the patent's prosecution history in deciding that its claim did not extend to cover Actavis's variant. This comes close to the US approach criticized by Lord Hoffmann in Kirin-Amgen and may lead to a resurrection of the Protocol Questions as a doctrine of equivalence, even if not explicitly recognized as such.

Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.

Full frame distilled prediction

Teacher imitation

Not calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.

metaresearch head score (Codex)0.001
metaresearch head score (Gemma)0.011
Version: codex-gemma-dda1882f352aValidation status: machine_predicted_unvalidated
Candidate categoriesMetaresearch, Insufficient payload (model declined to judge)
Consensus categoriesnone
DomainCandidate signal: none · Consensus signal: none
Study designCandidate signal: Not applicable · Consensus signal: Not applicable
GenreCandidate signal: Empirical · Consensus signal: none
Teacher disagreement score0.959
Threshold uncertainty score0.997

Codex and Gemma teacher scores by category

CategoryCodexGemma
Metaresearch0.0010.011
Meta-epidemiology (narrow)0.0000.000
Meta-epidemiology (broad)0.0000.000
Bibliometrics0.0000.000
Science and technology studies0.0000.000
Scholarly communication0.0000.002
Open science0.0000.000
Research integrity0.0000.001
Insufficient payload (model declined to judge)0.0040.000

Machine scores (provisional)

The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.

Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.

Opus teacher head0.057
GPT teacher head0.250
Teacher spread0.194 · how far apart the two teachers sit on this one work
Validation statusscore_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from it