Date: 20080725
Docket: A-383-07
Citation: 2008 FCA 244
CORAM: LÉTOURNEAU
J.A.
NADON
J.A.
PELLETIER J.A.
BETWEEN:
ATTORNEY GENERAL OF CANADA and
THE MINISTER OF HEALTH
Appellants
and
ABBOTT LABORATORIES LIMITED,
TAP PHARMACEUTICALS INC. and
TAP PHARMACEUTICAL PRODUCTS INC.
Respondents
REASONS FOR JUDGMENT
PELLETIER J.A.
INTRODUCTION
[1]
This
is an appeal from the decision of Madam Justice Simpson in Abbott
Laboratories Ltd. v. Canada (Attorney General) reported at 2007 FC 797, 315
F.T.R. 263, in which she quashed the decision of the Minister of Health deleting
Canadian Patent No. 2,269,053 (the '053 patent) from the Patent Register
maintained under the Patented Medicines (Notice of Compliance) Regulations,
S.O.R./93-133 (the Regulations). The issue in this appeal is whether the
Minister properly applied recent amendments to the Regulations relating to the
listing of patents "against" supplementary new drug submissions.
FACTS
[2]
The
following description of the links between the three respondents is taken from
Simpson J.'s Reasons for Judgment (the Reasons):
[8] TAP
Pharmaceuticals Inc. (TAP) is the party which files submissions and receives
Notices of Compliance for PREVACID(R) [the drug in issue] products in Canada. However,
TAP does not have a regulatory affairs department in Canada. For this
reason, Abbott Laboratories Limited (Abbott Canada) acts as TAP's agent in Canada for all
matters relating to TAP's submissions. In the case of PREVACID(R) Abbott Canada acted as TAP's
agent for the filing of the NSAID* SNDS** and the submission of the Patent List.
[9] TAP Pharmaceutical
Products Inc. (TAP Products) is a holding company for TAP. TAP Products is a
joint venture between Takeda Pharmaceutical Company Limited and Abbott
Laboratories. The latter is the American parent of the Applicant, Abbott Canada.
* Non-Steroidal Anti-Inflammatory
Drug (NSAID)
** Supplement to a New Drug Submission
(SNDS)
[3]
For
the sake of convenience, and since their interests seem to be identical, I will
simply refer to the respondents collectively as Abbott.
[4]
The
Regulations incorporate a scheme by which pharmaceutical products are brought
to market. They are intended to address both the health and safety concerns
regulated by the Food and Drugs Act, R.S.C. 1985, c. F-7, and its
regulations, the Food and Drug Regulations, C.R.C., c. 870, as well as
the rights of patent holders as set out in the Patent Act, R.S.C. 1985,
c. P-4. For a description of the broad outlines of the scheme, see paragraphs 3
to 21 of this Court's reasons in Wyeth Canada v. Ratiopharm Inc., 2007
FCA 264, 60 C.P.R. (4th) 375 (Wyeth Canada).
[5]
In
this case, the issue is the applicability of certain amendments to the
Regulations. To assist in following the thread of events, I shall refer to the
Regulations as they existed on June 15, 2006, as the Pre-amendment Regulations.
On June 16, 2006, the Minister published proposed amendments to the Regulations
in the Canada Gazette (Volume 140, number 24 of Part I). These took the form of
regulations amending the Regulations. I shall refer to the regulations published
on June 16, 2006, as the Amending Regulations. Finally, on October 5, 2006, the
Amending Regulations entered into force which resulted in the Regulations in
their current form.
[6]
On
May 12, 1995, the Minister issued a Notice of Compliance with respect to the
drug PREVACID for use in the treatment of duodenal ulcers, gastric ulcers, and
reflux esophagitis. The active medicinal ingredient in PREVACID is lansoprazole.
On April 2, 2000, Abbott filed an SNDS seeking approval for a new indication
for PREVACID, namely "Healing of NSAID-associated gastric ulcer and
reduction of risk of NSAID-associated gastric ulcer".
[7]
Both
the Pre-amendment Regulations and the Regulations authorized Abbott to submit a
patent list in respect of a new drug submission or an SNDS (generically, a
submission) either at the time of the filing of the submission, or if the
patent had not yet been issued, within 30 days of the issuance of the patent
but only if the application for the patent was made prior to the filing date of
the submission. The application for the '053 patent was filed in the Canadian
Patent Office on November 13, 1997 and the patent itself was issued on July 18,
2006. As a result, the '053 patent was not eligible to be included on a patent
list with respect to the original submission for a Notice of Compliance because
the patent application date did not precede the date of filing of the original
submission, i.e. prior to May 12, 1995. However, the patent application date,
November 13, 1997, did precede the date of the filing of the SNDS with respect
to the new indication for PREVACID, April 2, 2000, so that, from the point of
view of timeliness, the '053 patent was eligible to be included on a patent
list with respect to that SNDS.
[8]
The
patent list containing the '053 patent was filed on July 20, 2006 [July 19, 2006,
according to the Abbott's Brief] within 30 days of the issuance of the patent. It
is common ground that the '053 patent satisfied the other condition for the
listing of a patent in that it contained "a claim for the use of the medicine"
as provided in paragraph 4(2)(b) of the Pre-amendment Regulations. The '053
patent was included on the Patent Register on July 25, 2006, in relation to the
SNDS for the new indication for PREVACID.
[9]
The
Amending Regulations amended the listing requirements in section 4 of the
Pre-amendment Regulations and, in particular, set out the types of SNDS's
against which a patent list could be submitted:
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4. (3) A patent on a
patent list in relation to a supplement to a new drug submission is eligible
to be added to the register if the supplement is for a change in formulation,
a change in dosage form or a change in use of the medicinal ingredient, and
(a) in the case
of a change in formulation, the patent contains a claim for the changed
formulation that has been approved through the issuance of a notice of
compliance in respect of the supplement;
(b) in the case
of a change in dosage form, the patent contains a claim for the changed
dosage form that has been approved through the issuance of a notice of
compliance in respect of the supplement; or
(c) in the case
of a change in use of the medicinal ingredient, the patent contains a claim
for the changed use of the medicinal ingredient that has been approved
through the issuance of a notice of compliance in respect of the supplement.
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4. (3) Est admissible à l’adjonction au registre tout brevet, inscrit sur une
liste de brevets, qui se rattache au supplément à une présentation de drogue
nouvelle visant une modification de la formulation, une modification de la
forme posologique ou une modification de l’utilisation de l’ingrédient
médicinal, s’il contient, selon le cas :
a) dans le cas d’une modification de formulation, une revendication de la
formulation modifiée, la formulation ayant été approuvée par la délivrance
d’un avis de conformité à l’égard du supplément;
b) dans le cas d’une modification de la forme posologique, une
revendication de la forme posologique modifiée, la forme posologique ayant
été approuvée par la délivrance d’un avis de conformité à l’égard du
supplément;
c) dans le cas d’une modification d’utilisation de l’ingrédient
médicinal, une revendication de l’utilisation modifiée de l’ingrédient
médicinal, l’utilisation ayant été approuvée par la délivrance d’un avis de
conformité à l’égard du supplément.
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[10]
The
Amending Regulations contained certain transitional provisions. Section 6 of
the Amending Regulations provided that the amendments to section 4, including
those quoted above, did not apply to a patent on a patent list submitted prior
to June 17, 2006. Section 7 of the Amending Regulations provided that they
applied to submissions made prior to the coming into force of the Amending
Regulations and further, that the date of filing of such submissions was deemed
to be the date of the coming into force of the Amending Regulations, namely
October 5, 2006. On the face of section 6 of the Amending Regulations, section
4 of the Regulations applied to the '053 patent because it was on a patent list
submitted after June 17, 2006.
[11]
Notwithstanding
the inclusion of the '053 patent on the Patent Register, the Minister
determined on March 2, 2007, that the '053 patent did not meet the requirements
of section 4(3)(c) of the Regulations, as it did not contain a claim for
the changed use of the medicinal ingredient. As a result, the Minister deleted
the '053 patent from the Patent Register on March 2, 2007 [February 22
according to the Minister's Brief].
[12]
In doing
so, the Minister purported to exercise the power and duty conferred on him by
section 3 of the Regulations, as amended, which provides as follows:
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3. (2) The Minister shall maintain a
register of patents and other information submitted under section 4. To
maintain the register, the Minister may refuse to add or may delete any
patent or other information that does not meet the requirements of that
section.
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3. (2) Le ministre
tient un registre des brevets et des autres renseignements fournis aux termes
de l'article 4. À cette fin, il peut refuser d'y ajouter ou en supprimer tout
brevet ou tout autre renseignement qui n'est pas conforme aux exigences de
cet article.
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[13]
Abbott
brought an application for judicial review of the Minister's decision. It made
two arguments: first, that the amendments to the Regulations did not apply to
the patent list submitted on July 25, 2006, and second, that, in any event, the
'053 patent did contain a claim for the changed use of the medicinal
ingredient.
THE DECISION UNDER APPEAL
[14]
Simpson J.
noted that the parties agreed that the interpretation of the Regulations was a
question of law and that the standard of review was therefore correctness.
[15]
On the
issue of whether the July 25, 2006 patent list was subject to the amendments
introduced by the Amending Regulations, Abbott made five arguments, all of
which were rejected by Simpson J.
[16]
Abbott's
first argument was that the plain meaning of the Regulations made it clear that
they were not intended to apply to the removal of patents from the Patent Register.
Paragraph 4(3)(c) of the Regulations deals only with the inclusion of
patents to the Patent Register. Abbott argues, as a result, that paragraph
4(3)(c) cannot be invoked to justify deleting a patent from the Patent Register.
[17]
Simpson J.
found that this argument was inconsistent with subsection 3(2) of the
Regulations dealing with the maintenance of the Patent Register. She found that
"the words of subsection 3(2), when read in their context and in their
ordinary sense, have the effect of cross referencing the requirements for
adding patents in section 4 so that they also become the requirements for the
deletion of patents under subsection 3(2)": see paragraph 24 of Simpson J.'s
Reasons.
[18]
Simpson J.
also rejected Abbott's argument that the deletion of the '053 patent from the
Patent Register amounted to giving retroactive effect to the amendments to the
Regulations. A related argument to the effect that Parliament had not
authorized the Minister to interfere with vested rights was also dismissed.
[19]
In
rejecting the argument as to the retroactive application of the amendments,
Simpson J. relied, correctly in my view, on the decision of this Court in Eli
Lilly Canada Inc. v. Canada (Minister of Health), 2003 FCA 24, [2003] 3 F.C.
140 (Eli Lilly), in which it was held that the Minister is entitled to
require that patents on the Patent Register satisfy the regulatory requirements
as they exist from time to time, so that past compliance with the regulatory
requirements does not, in and of itself, exempt a patent from compliance with
any subsequently enacted listing requirement. Eli Lilly disposes as well
of the argument as to vested rights.
[20]
Abbott
then argued that the Amending Regulations must be read in light of the
transitional provisions and, in particular, section 7 which provides as
follows:
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7. (1) Subsection 5(1) of the Patented Medicines (Notice of Compliance)
Regulations, as enacted by section 2 of these Regulations, applies
to a second person who has filed a submission referred to in subsection 5(1)
prior to the coming into force of these Regulations and the date of filing of
the submission is deemed to be the date of the coming into force of these
Regulations.
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7. (1) Le paragraphe 5(1) du Règlement sur les
médicaments brevetés (avis de conformité), édicté par l'article 2 du présent règlement, s'applique
à toute seconde personne qui a déposé une présentation visée à ce paragraphe
avant l'entrée en vigueur du présent règlement, et la date de dépôt de cette
présentation est réputée être la date d'entrée en vigueur du présent
règlement.
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[21]
In
Abbott's view, this disposition was intended to "freeze" the register
by requiring the second person to address all patents on the Patent Register as
of the coming into force of the amendments to the Regulations. Simpson J.
disposed of this argument by holding that it was intended to have the second
person address all patents which were properly on the Patent Register as of the
material date. In her view, allowing the Minister to remove patents which did
not meet the criterion for inclusion on the Patent Register did not offend the
letter or the spirit of the transitional provision.
[22]
Finally,
Abbott argued that since the Patent Office approved its patent application on
May 12, 2006 (the date of the issuance of the Notice of Allowance), but did not
actually issue the patent until July 18, 2006, it should be treated as though
its rights were fixed as of the date of the Notice of Allowance. Otherwise, it
said, it was being penalized for the delay in the Patent Office. Simpson J.
rejected this argument on the ground that there was no basis for deeming a
patent list to have been filed when no list was filed, whatever the merits of
the claim of delay in the Patent Office.
[23]
Having
disposed of the timeliness argument, Simpson J. then dealt with Abbott's substantive
argument which was that, in any event, the '053 patent did contain a claim for
the changed use of lansoprazole and, therefore, should not have been deleted
from the Patent Register. Abbott relies upon the opinions of two experts, one a
physician, the other a chemist. Both agreed that the patent contained a claim
for the treatment of ulcers and that a person skilled in the art would
recognize that "ulcers" included "non steroidal
anti-inflammatory drug" ulcers.
[24]
Simpson
J. accepted this argument, saying:
[41] In my view, it is consistent with
the expert evidence to conclude that the 053 Patent is eligible to be on the
Patent Register pursuant to paragraph 4(3)(c) of the New Regulations because it
includes a claim for the new use of lansoprazole to treat NSAID ulcers.
[25]
Simpson J.
also rejected the Minister's argument that the '053 patent was not eligible for
inclusion on the Patent Register because it was a patent for a polymorphic form
of lansoprazole:
New patents claiming
novel physical forms of the approved medicinal ingredient will not be eligible
for listing in this manner.
[Regulatory
Impact Analysis Statement "Changes to the patent listing requirements."]
[26]
In Simpson
J.'s view, the fact that the patented invention was a polymorphic form of
lansoprazole did not disqualify the patent from inclusion on the Patent
Register.
[27]
As a
result, Simpson J. found that the Minister erred in deleting the '053 patent
from the Patent Register and ordered it to be restored to the Patent Register.
ANALYSIS
[28]
The issues
to be decided in this appeal are the following:
1- What is
the standard of review of the Minister's decision?
2- Do the
2006 amendments apply to the deletion of the '053 patent from the Patent
Register?
3- If they
do, is the Minister's decision to delete the '053 patent from the Patent
Register reviewable?
1- What is the standard of review of the Minister's
decision?
[29]
Simpson J.
proceeded on the basis that the parties had agreed that since the issue before
the Minister was a question of law, the standard of review was correctness.
[30]
The
Minister says that he did not agree that the question before him was a pure
question of law. His position is:
…unlike the many patent
listing cases brought under the previous versions of the PM(NOC) Regulations,
the question of whether the '053 patent is eligible for listing on the Patent
Register under the amended regulatory scheme is not wholly a question of law. Pursuant
to the new requirements introduced under subsection 4(3) of the amended PM(NOC)
Regulations, the eligibility of a patent for listing on the Patent Register
in connection with a SNDS now explicitly requires an assessment of the subject-matter
of the drug submission against which the patent is proposed to be listed. Such
an assessment is a question of fact and is one that falls squarely within the
expertise of the Minister. Therefore, it is submitted that a question of patent
eligibility under subsection 4(3) of the amended PM(NOC) Regulations is
properly characterized as a question of mixed fact and law…
[31]
The
standard of review applicable to questions of mixed fact and law at the time
the Minister's Brief was written was, he says, patent unreasonableness: see Ferring
Inc. v. Canada (Minister of Health), 2007 FCA 276, 60 C.P.R. (4th)
273. Since then, the legal landscape has changed with the Supreme Court's
decision in Dunsmuir v. New Brunswick, 2008 SCC 9, [2008] S.C.J. No. 9 (Dunsmuir), which
redefined the range of standards of review from three (patent unreasonableness
through reasonableness to correctness) to two (unreasonableness and correctness).
Taking Dunsmuir into account, the Minister's position is that the
appropriate standard of review is unreasonableness.
[32]
The
Minister's argument rests on the fallacy that there is a difference in kind
between deciding if an SNDS contains "a claim for the
medicine itself or a claim for the use of the medicine" as subsection 4(2) of the
Pre-amendment Regulations required, and deciding if "in the case of
a change in use of the medicinal ingredient, the patent contains a claim for
the changed use of the medicinal ingredient that has been approved through the
issuance of a Notice of Compliance in respect of the supplement" as
subsection 4(3) of the Regulations now require. While the content of the
inquiry which the Minister is required to undertake has changed, the nature of
the inquiry is the same. It is whether the content of the submission satisfies
the legal criteria for listing. The change in the Regulations has not made the
inquiry any more fact specific than it previously was: there is no meaningful
legal distinction to be drawn between deciding if the claims of a patent
contain "a claim for the use of the medicine" as opposed to "a
claim for the changed use of the medicinal ingredient".
[33]
The
jurisprudence of this Court establishes that the standard of review of a
decision to list, or to refuse to list, a patent on the Patent Register is
correctness: see Eli Lilly, at paragraph 5. Dunsmuir teaches that
we may look to the jurisprudence for guidance as to the appropriate standard of
review: see Dunsmuir, at paragraph 57. I see no merit in the Minister's
suggestion that the amendments to the Regulations have the effect of changing
the standard of review which, in my view, remains correctness.
2- Do the 2006 amendments apply to the
deletion of the '053 patent from the Patent Register?
[34]
The many
arguments which Abbott has raised on this issue amount to one argument on
statutory interpretation and a series of arguments premised on a finding that
the statutory language is ambiguous. If it is not ambiguous, then there is no
need to resort to presumptions against retroactivity or interference with
vested rights. For example, the presumption against retroactive legislation was
expressed as follows in Gustavson Drilling (1964) Ltd. v. Canada (Minister
of National Revenue - M.N.R.), [1977] 1 S.C.R. 271, at page 279:
The general
rule is that statutes are not to be construed as having retrospective operation
unless such a construction is expressly or by necessary implication required by
the language of the Act.
[35]
In Sullivan, Driedger
on the Construction of Statutes (3rd Ed.) (Butterworths,
Toronto, 1994) at page 512, the author points out that the term
"retrospective" in the passage cited above should be
"retroactive".
[36]
In other
words, Parliament can indeed legislate retroactively providing that it makes
its intention to do so unmistakably clear.
[37]
In the
present case, there is no ambiguity which leaves room for the application of
any presumption. The Minister's authority to remove a patent from the Patent
Register is found in section 3 of the Regulations, quoted above but reproduced
here for ease of reference:
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3. (2) The Minister shall maintain a
register of patents and other information submitted under section 4. To
maintain the register, the Minister may refuse to add or may delete any
patent or other information that does not meet the requirements of that
section.
|
3. (2) Le Ministre
tient un registre des brevets et des autres renseignements fournis aux termes
de l'article 4. À cette fin, il peut refuser d'y ajouter ou en supprimer tout
brevet ou tout autre renseignement qui n'est pas conforme aux exigences de
cet article.
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[38]
The power
to delete patents from the Patent Register is not subject to any transitional
provision. It is therefore subject to the principle embodied in section 10 of
the Interpretation Act, R.S.C. 1985, c. I-21:
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10. The law shall be
considered as always speaking, and
where a matter or thing is expressed in the present tense, it shall be
applied to the circumstances as they arise, so that effect may be given to
the enactment according to its true spirit, intent and meaning.
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10. La règle de droit
a vocation permanente; exprimée dans un texte au présent intemporel, elle s'applique
à la situation du moment de façon que le texte produise ses effets selon son
esprit, son sens et son objet.
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[39]
Section 3
therefore looks to the requirements of section 4 as they exist at any given
point in time. Thus, when the Minister re-examined the listing of the '053
patent in light of the amendments which came into effect in October 2006, section
4 of the Regulations required the '053 patent to contain a claim for the
changed use of the medicinal ingredient identified in the SNDS against which it
was filed. The Minister concluded that the '053 patent did not contain such a
claim and that as a consequence, it was ineligible for listing as of the date
of examination, and therefore liable to be deleted from the Patent Register. None
of this gives rise to the least ambiguity.
[40]
Abbott
invokes the transitional provisions of the Amending Regulations and, in
particular, section 6 which provides as follows:
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6. Section 4 of the Patented Medicines (Notice of Compliance)
Regulations, as enacted by section 2 of these Regulations, does not
apply to patents on a patent list submitted prior to the day, in 2006, on
which these Regulations are published in Part I of the Canada Gazette.
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6. L'article 4 du Règlement sur les
médicaments brevetés (avis de conformité), édicté par l'article 2 du présent règlement, ne s'applique pas aux
brevets inscrits sur la liste de brevets présentée avant la date de
publication, en 2006, du présent règlement dans la partie I de la Gazette
du Canada.
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[41]
Abbott
argues that there is a gap created by the operation of section 6. Patent lists
submitted after June 17, 2006, but which are added to the Patent Register prior
to October 6, 2006, fall in this gap. They are added to the Patent Register
according to the "old" rules but are subject to being removed
according to the "new" rules. Abbott says that this kind of "in
and out" scenario cannot have been intended by the legislator.
[42]
In fact,
it is passably clear that it was intended. Section 6 of the Amending
Regulations uses as its reference date the filing date of a patent list. Had it
been intended to protect all patents listed on the Patent Register as of the
coming into force of the amendments, it would have been simple enough to say so.
Abbott's argument, if accepted, would achieve that result without the benefit
of enabling legislation. It is clear, though, that by using the filing date of
the patent list as the reference date for the application of section 4, the
legislator specifically allowed for the kind of re-examination
which occurred here.
[43]
In the end
result, given the clear language of section 3 of the Regulations, I am
satisfied that the Minister correctly decided that the Regulations applied to
the '053 patent.
3. If they do, is the Minister's decision to delete the '053 patent from
the Patent Register reviewable?
[44]
Abbott
says that even if the amendments to the Regulations apply to the listing of the
'053 patent, it meets those requirements. Simpson J. accepted this argument on
the strength of expert evidence which essentially said that a claim for the
treatment of ulcers includes a claim for the treatment of NSAID ulcers.
[45]
The
redrafting to section 4 of the Regulations into its current form comes in
response to a running debate about the "relevance" of patents in
relation to the submissions against which drug manufacturers seek to list them:
see for example, Eli Lilly, at paragraphs 30 to 39.
[46]
That
controversy was resolved by amendments which specified the characteristics of
patents which could be listed against specific types of SNDS's. Thus, where a
manufacturer submitted an SNDS with respect to a new dosage form, the
Regulations now require any patent sought to be filed against that submission
to contain "a claim for the changed dosage form…": see paragraph
4(3)(b) of the Regulations. In the present case, the SNDS in question is
with respect to a new indication for an existing drug PREVACID. That drug was
originally approved for use in the treatment of "duodenal ulcers, gastric
ulcers, and reflux esophagitis". The SNDS relevant to these proceedings
claims as a new indication for the drug "Healing of NSAID-associated
gastric ulcer and reduction of risk of NSAID-associated gastric ulcer". Paragraph
4(3)(c) of the Regulations requires that any patent sought to be listed
on the Patent Register against that submission must contain "a claim for
the changed use of the medicinal ingredient".
[47]
It stands
to reason that if a patent must contain a claim for the changed use identified
in Abbott's SNDS, that patent cannot simply claim the use which formed the
basis of the original submission. Such a patent does not specifically claim the
changed use, even though the changed use may come within the claims of the
patent. In other words, the Regulations envisage as a condition of listing a
patent in respect of a change in the use of a medicinal ingredient that the
patent specifically claims the changed use as opposed to non-specific claims
which are wide enough to include the changed use.
[48]
It is this
distinction between specific claims and broad non-specific claims which led to
the discussion in the jurisprudence about the nature of the patented invention:
see Wyeth Canada, at paragraph 22, affirmed [2007] F.C.J. No. 1062 at
paragraph 29. That discussion has now been overtaken by the amendments to the
Regulations.
[49]
Even if
one were inclined to look to the nature of the invention, the difficulty is
that the language of the Regulations speaks only of "a claim for the
changed use of the medicinal ingredient". I conclude that paragraph 4(3)(c)
of the Regulations requires, as a condition of listing a patent on the Patent
Register, that the patent must specifically claim the very change in use which
was approved by the issuance of a Notice of Compliance with respect to an SNDS.
[50]
As
a result, I am of the view that Simpson J. erred in accepting the expert
opinions which were placed before her as evidence that the '053 patent
contained a claim for the changed use of the medicinal ingredient in PREVACID. That
evidence went no further than showing that the '053 patent would have been
eligible for listing against the original submission for PREVACID, had it not
been for the fact that the date of the submission preceded the date of the
patent application. To allow registration of the '053 patent against the SNDS
for a changed use which was not the subject of a specific claim would be to
undo the reform which the amended regulations seek to introduce. For that
reason, I would allow the appeal with costs and set aside the decision of the
Federal Court. I would dismiss with costs the respondent’s application for
judicial review.
“J.D.
Denis Pelletier”
“I
agree.
Gilles Létourneau J.A.”
“I
agree.
M. Nadon J.A.”
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