Sonani Industries Pvt Ltd Patent Infringement Case pertaining to High Pressure High Temperature (HPHT) treatment of diamonds
The Hon'ble Division Bench, High Court of Gujarat recently delivered a judgment on July 19, 2024, in the patent infringement case involving Sonani Industries Pvt Ltd (formerly Sonani Jewels Pvt. Ltd.) and Galactica Processing Technologies LLP & Ors.. This appeal AO No. 139 of 2023 concerns a challenge to an order by the Additional District Judge in Surat regarding a patent infringement case of Sonani Industries Pvt Ltd's registered patent, IN 398302 [The patent.]"
Background:
The nature of the dispute between Sonani Industries Pvt. Ltd. and Galactica Processing Technologies LLP & Ors. revolves around allegations of patent infringement and misappropriation of proprietary information. Sonani Industries hold a patent for a diamond holding device used in the High Pressure High Temperature (HPHT) treatment of diamonds, which is crucial for maintaining diamond quality during the treatment process.
The Trial Court Order:
Sonani Industries Pvt. Ltd was Plaintiff in Trial Court and Appellant in the subject matter Appeal , while Galactica Processing Technologies and Ors are Defendants in the Trial Court Suit proceeding and Respondents in the instant Appeal. The trial court rejected Appellant's injunction application, prompting the appeal.
Appellant's contention:
Sonani Industries alleged that Galactica Processing Technologies LLP & Ors have infringed upon their patent (IN398302) for a diamond holding device used in the HPHT treatment of diamonds. This device is designed to withstand extreme pressure and temperature, which is essential for maintaining diamond quality during the HPHT process. The Appellant alleged that the Respondents were aware of the Appellant's know-how, technical details, proprietary rights, and confidential information while employed by the Appellant, and they have breached their obligation of confidentiality by using this information for their own benefit.
Respondents' Contention:
On the other hand, the Respondents argued that the patent held by Appellant was not novel and that the technology described in the patent was already known and used before the patent's priority date. This challenges the validity of the patent itself. The Respondents claim that the technology in question is based on prior art, specifically referring to a design from 'V. Bakul Institute for Superhard Materials NAS of Ukraine' (Bakul), which was already published and is in the public domain.
The Court's Approach in evaluating the aspect of Patent Infringement:
The court analysed the prior arts provided by the Respondents, such as the Bakul patent, which they claimed disclosed similar or identical technology to the suit patent. The court assessed these documents to determine if they indeed showed a high degree of similarity to the suit patent, as claimed by the Respondents. The court conducted a technical comparison between the suit patent and the prior arts cited. This involved looking at the structural components, functions, and overall design of the diamond holding devices to see if there were substantial differences that would establish the novelty of the suit patent. The court also examined whether the suit patent represented a significant improvement over existing technology or if it was merely a workshop improvement on the Bakul patent, which would not qualify as an invention. These were the basic approach on which the Hon'ble Division Bench focussed while evaluating the aspect of Patent Infringement as claimed by the Appellant.
The Final Analysis:
In the final analysis, the court found that Appellant did not establish a prima facie case for the novelty and inventiveness of the suit patent in light of the prior arts cited by the Respondents. The court's analysis indicated that the Respondents had raised a credible challenge to the validity of the patent by showing that there was a serious question regarding the patent's vulnerability to challenge based on the prior arts. This led to the dismissal of the appeal and the rejection of the injunction application filed by the Appellant.
Implication:
The judgment could influence market competition by potentially allowing multiple players to use similar technologies, as long as they can demonstrate that they are not infringing on valid patents. This could lead to a more competitive market with various companies offering similar services. The case may lead to a greater demand for legal and technical expertise within the diamond industry in Surat, as companies seek to navigate the complexities of patent law and to defend their intellectual property rights.
Written By: Advocate Ajay Amitabh Suman
Patent and Trademark Attorney
United & United
The Hon'ble Division Bench, High Court of Gujarat recently delivered a judgment on July 19, 2024, in the patent infringement case involving Sonani Industries Pvt Ltd (formerly Sonani Jewels Pvt. Ltd.) and Galactica Processing Technologies LLP & Ors.. This appeal AO No. 139 of 2023 concerns a challenge to an order by the Additional District Judge in Surat regarding a patent infringement case of Sonani Industries Pvt Ltd's registered patent, IN 398302 [The patent.]"
Background:
The nature of the dispute between Sonani Industries Pvt. Ltd. and Galactica Processing Technologies LLP & Ors. revolves around allegations of patent infringement and misappropriation of proprietary information. Sonani Industries hold a patent for a diamond holding device used in the High Pressure High Temperature (HPHT) treatment of diamonds, which is crucial for maintaining diamond quality during the treatment process.
The Trial Court Order:
Sonani Industries Pvt. Ltd was Plaintiff in Trial Court and Appellant in the subject matter Appeal , while Galactica Processing Technologies and Ors are Defendants in the Trial Court Suit proceeding and Respondents in the instant Appeal. The trial court rejected Appellant's injunction application, prompting the appeal.
Appellant's contention:
Sonani Industries alleged that Galactica Processing Technologies LLP & Ors have infringed upon their patent (IN398302) for a diamond holding device used in the HPHT treatment of diamonds. This device is designed to withstand extreme pressure and temperature, which is essential for maintaining diamond quality during the HPHT process. The Appellant alleged that the Respondents were aware of the Appellant's know-how, technical details, proprietary rights, and confidential information while employed by the Appellant, and they have breached their obligation of confidentiality by using this information for their own benefit.
Respondents' Contention:
On the other hand, the Respondents argued that the patent held by Appellant was not novel and that the technology described in the patent was already known and used before the patent's priority date. This challenges the validity of the patent itself. The Respondents claim that the technology in question is based on prior art, specifically referring to a design from 'V. Bakul Institute for Superhard Materials NAS of Ukraine' (Bakul), which was already published and is in the public domain.
The Court's Approach in evaluating the aspect of Patent Infringement:
The court analysed the prior arts provided by the Respondents, such as the Bakul patent, which they claimed disclosed similar or identical technology to the suit patent. The court assessed these documents to determine if they indeed showed a high degree of similarity to the suit patent, as claimed by the Respondents. The court conducted a technical comparison between the suit patent and the prior arts cited. This involved looking at the structural components, functions, and overall design of the diamond holding devices to see if there were substantial differences that would establish the novelty of the suit patent. The court also examined whether the suit patent represented a significant improvement over existing technology or if it was merely a workshop improvement on the Bakul patent, which would not qualify as an invention. These were the basic approach on which the Hon'ble Division Bench focussed while evaluating the aspect of Patent Infringement as claimed by the Appellant.
The Final Analysis:
In the final analysis, the court found that Appellant did not establish a prima facie case for the novelty and inventiveness of the suit patent in light of the prior arts cited by the Respondents. The court's analysis indicated that the Respondents had raised a credible challenge to the validity of the patent by showing that there was a serious question regarding the patent's vulnerability to challenge based on the prior arts. This led to the dismissal of the appeal and the rejection of the injunction application filed by the Appellant.
Implication:
The judgment could influence market competition by potentially allowing multiple players to use similar technologies, as long as they can demonstrate that they are not infringing on valid patents. This could lead to a more competitive market with various companies offering similar services. The case may lead to a greater demand for legal and technical expertise within the diamond industry in Surat, as companies seek to navigate the complexities of patent law and to defend their intellectual property rights.
Written By: Advocate Ajay Amitabh Suman
Patent and Trademark Attorney
United & United
