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2026-04
One Case a Day | China: Technical Features of Numerical Ranges - (2021) Supreme People's Court Zhixing Zhong No. 349
Case Introduction
Today's shared case is a typical case from the 2021 Summary of Key Rulings of the Supreme People's Court Intellectual Property Tribunal, involving the distinction between two types of technical features: natural number intervals and continuous physical quantity numerical ranges. The judgment points out: numerical ranges defining the quantity of mechanical components are natural number intervals, which differ from numerical ranges of continuous physical quantities such as length; technical features defining the quantity of mechanical components with numerical ranges should, in principle, be regarded as a collection of parallel technical means rather than a single technical means. When a prior art document only discloses one or some of the quantities, it is insufficient to claim that the document has directly disclosed the other parallel technical means defined by this technical feature.
The conclusion of this case is not the most important; its significance lies in clearly pointing out the understanding of the two types of numerical range technical features, which can better guide corresponding practices in infringement and validity determination procedures.
Case Information
- Application Number: 2014101418005
- Title of Invention: Manual Braking Structure for Three-Wheeled Motorcycles, Electric Tricycles, and Diesel Tricycles
- Priority Date: April 2, 2013
- Reexamination Decision Number: No. 183664
- First-Instance Judgment: (2019) Jing 73 Xing Chu No. 12584
- Second-Instance Judgment: (2021) Supreme People's Court Zhixing Zhong No. 349
- Judgment Date: October 25, 2023
Key Points of the Case
The involved claims contain two technical features with numerical ranges:
- f1: containing at least 2 levers;
- f2: 5.7 ≤ quotient < 5.9.
As the closest prior art, Evidence 1 discloses a technical solution containing 4 levers, and the quotient related to f2 discloses a single point value of 5.824.
Regarding this, the second-instance court held:
The quantity of mechanical components is a natural number, which differs from continuous physical quantities such as length, temperature, pressure, content, and time. Therefore, the understanding of technical features defining the quantity of mechanical components with numerical ranges should differ from that of technical features defining continuous physical quantities.
For the latter (f2), it should be regarded as a single technical feature. When the numerical value or numerical range disclosed in a prior art document falls within the numerical range defined by the above technical feature, it can be determined that the prior art document has disclosed this technical feature.
However, for technical features defining the quantity of mechanical components with numerical ranges (f1), they should be regarded as a collection of parallel technical means. When a prior art document only discloses one or some of the quantities, it is insufficient to claim that the document has disclosed the other parallel technical means defined by this technical feature.
In this case, the object defined by the numerical range technical feature "containing at least two levers" in the claims of this application is the quantity of levers. Therefore, this technical feature should be regarded as a collection of parallel technical means. Technical feature f2 in the claims of this application is a ratio of a continuous physical quantity, which also has a continuous nature. Therefore, the quotient range defined in the claims of this application should be regarded as a single technical feature.
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