Australia: Supporting evidence in patent specifications

Managing IP is part of Legal Benchmarking Limited, 1-2 Paris Gardens, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Australia: Supporting evidence in patent specifications

The recent Full Federal Court case of Morellini v Mizzi Family Holdings Pty Ltd [2016] FCAFC 13 has highlighted the danger of using unsupported assertions in patent specifications.

The technology of the case dealt with sugar cane planting, with the applicant committing a fatal error in asserting: "it is found that" inclining a soil mound by about 40 degrees provided superior warming of the soil by the sun.

During prosecution, the applicant had argued the soil mound inclination was a significant feature of the claim that distinguished it from the prior art.

The problem was that there was no evidence that the soil mound incline had any effect on heating of the soil. The applicant tried to argue that this was part of their "own experience and conclusions". However the Court rejected this argument as totally speculative.

The Court concluded the patent was invalid for false suggestion or misrepresentation. Hence, the applicant's somewhat innocuous use of the term "it has been found", rather than say "it is conjectured, thought or believed", has led to the destruction of its patent rights.

The obvious takeaway from the case is to review specifications to revise assertions that are not backed by evidence.

treloar.jpg

Peter Treloar


Shelston IPLevel 21, 60 Margaret StreetSydney NSW 2000, AustraliaTel: +61 2 9777 1111Fax: +61 2 9241 4666email@shelstonip.comwww.shelstonip.com

more from across site and SHARED ros bottom lb

More from across our site

Sources say the judge could return to a disputes or mediation-focussed role, though others have questioned whether the Texas court will remain a litigation hotspot in his absence
Sheppard, which has hired 14 IP partners in the last 12 months, has cited client demand for expert counsel in SEP, ITC, and district court disputes
Tingxi Huo joins our ‘Five minutes with’ series to discuss boosting the value of clients’ IP and the importance of reflection
Hefty legal teams assembled for a three-day hearing in what was the court’s first foray into SEPs since Unwired Planet v Huawei
IP firm's new base will be located inside the tallest office space in the UK's ‘second city’
Practitioners at four firms across Asia and Europe share the do’s and don’ts of mindful networking ahead of the INTA Annual Meeting
Brand Action explains why the IP community can be a force for good in the world as thousands of professionals prepare to head to London for INTA’s Annual Meeting
The firm, which has also hired a senior trademark leader to lead operations in the region, believes greater China to be one of the most important IP jurisdictions
Attorneys at Gibson Dunn share why plaintiffs’ growing reliance on DMCA anti-circumvention claims in AI scraping cases exposes a critical vulnerability
Tom Carver, who spent the last 18 months sailing the Mediterranean, tells Managing IP why he’s ready to return to land
Gift this article