As is clear from the figure, the patent invalidation rate at the JPO was very high before 2008. Similarly, in patent infringement cases, many of the patentee's claims were dismissed due to patent being found invalid. However, the patent invalidation rate in the JPO has been declining since 2009 and the same trend is apparent in patent infringement cases. One of the reasons for this drastic change may be an IP High Court judgment in January 2009 by Judge Iimura, the current chief judge of the IP High Court. How did the way of determining inventive step in Japan change?