IPCC’s Reversed Judgment: Judicial Standards for "Reading-In Claims" and "Technical Equivalency" in the ASUS Case
Date: 29 May 2026
【Volume 171】
The Taiwan Intellectual Property and Commercial Court (IPCC) recently reversed a portion of the administrative disposition made by the Taiwan Intellectual Property Office (TIPO) in an invalidation case filed by Micro-Star International Co., Ltd. (MSI) against a utility model patent titled “INTERFACE CONNECTION STRUCTURE” owned by ASUSTeK Computer Inc. (ASUS) (IPCC 2025 Xing Zhuan Su Zi No. 37 Administrative Judgment). Although the patentee incorporated detailed structural features such as a "fastening portion" and a "pressing portion" into the dependent claims, these features failed to further define specific structures, operational methods, or relative spatial relationships. Consequently, the Court held that such fastening mechanisms merely constituted a routine transformation of conventional technical means that could be easily accomplished by a person ordinarily skilled in the art, thereby lacking an inventive step. The IPCC provided detailed explanations regarding claim interpretation, motivation to combine, and other related determinations in this case. The views in both judgments are highly worthy of reference.
【Case Overview】
The disputed patent was a utility model patent titled “INTERFACE CONNECTION STRUCTURE” (Registration No. M609050) filed by ASUS, primarily used for installation of M.2 interface devices (such as SSDs and network cards). MSI filed an invalidation request against the disputed patent. After examination, the Taiwan Intellectual Property Office (TIPO) (the defendant) determined that invalidation of Claims 1 to 3 and 8 to 11 of the disputed patent was established, whereas Claims 4 to 7 were maintained as valid and the invalidation action with respect thereto was dismissed.
ASUS and MSI respectively filed administrative litigations against portions of the original disposition unfavorable to each party, seeking revocation thereof. After review, the Intellectual Property and Commercial Court (IPCC) reversed part of the original disposition. The IPCC upheld invalidation of Claims 1 to 3 and 8 to 11(IPCC 2025 Xing Zhuan Su Zi No. 36 Administrative Judgment). However, with respect to Claims 4 to 7 of the disputed patent (involving details of fastening portions and pressing portions), the IPCC adopted a view different from that of TIPO and held that such claims lacked an inventive step and should therefore be revoked (IPCC 2025 Xing Zhuan Su Zi No. 37 Administrative Judgment). Ultimately, all 11 claims of the disputed patent were held invalid.
【Technical features and issues of the disputed patent】
The disputed patent was intended to address drawbacks associated with conventional M.2 SSD installation, such as small screw sizes, the need for tools during installation and removal, and the tendency of screws to be easily lost. The disputed patent claimed to achieve tool-free and rapid assembly/disassembly through a “rotation locker structure.”
MSI (the invalidation requester) submitted multiple prior art references (Evidence 2, 3, and 4), arguing that the technology merely involved simple substitution of an existing “tool-free nut” onto a motherboard circuit board and therefore lacked an inventive step.
【Core Views of the IPCC】
The IPCC demonstrated consistent principles of legal interpretation across both judgments, particularly with respect to “claim interpretation” and “equivalence of technical solutions”:
1. Prohibition Against “Improper Reading-In/Importation”: Legal Boundaries of Claim Interpretation
ASUS argued that its “rotation locker” was different from the “nut” disclosed in Evidence 4 because the disputed patent involved “single-handed fastening” and “rotation at the same height” without loosening.
IPCC’s View: The IPCC emphasized “the principle of prohibition against reading-in/importation.” Claim 1 merely recited “rotatably disposed,” and Claim 4 merely recited a “fastening portion.” The disputed patent did not define technical features such as “operational steps,” “single-handed operation,” or “rotation at the same height” in the claims. Therefore, the IPCC could not read details from the preferred embodiments disclosed in the specification into the claims in order to narrowly construe the claims to avoid the prior art.
2. Technical Equivalence Between “Fastening” and “Threaded Engagement”
ASUS argued that “fastening” referred to a non-threaded structure and was fundamentally different from the threaded engagement disclosed in Evidence 4.
IPCC’s View: The IPCC held that internal/external threading (threaded engagement) and snap-fit fastening (fastening) are both extremely common and well-established joining means in the relevant technical field. For a person ordinarily skilled in the art, changing an internal-threaded engagement structure into a fastening structure in order to achieve a “tool-free” objective constituted a “simple change” and an “equivalent substitution,” and therefore did not involve a significant technical breakthrough.
3. Motivation to Combine: Determination of Commonality of Technical Problems
ASUS argued that Evidence 4 related to a hard disk adapter board and therefore belonged to a different technical field from that of motherboards.
IPCC’s View: The IPCC held that Evidence 2, 3, and 4 all belonged to the technical field of “interface connection mechanisms.” More importantly, all three references addressed the common problem of “how to secure M.2 interface devices of different sizes.” Given the existence of a common technical problem, a person ordinarily skilled in the art would have had strong motivation to combine the tool-free component disclosed in Evidence 4 with the circuit board configurations disclosed in Evidence 2 and 3.
4. “Obviousness” of Structures Described in Dependent Claims
With respect to the “pivot portion” being disposed below, the “rotating portion” being disposed above, and the “hexagonal column shape” described in Claims 5 to 7, the IPCC held that changes in component arrangement positions (i.e., switching upper and lower positions) merely constituted “simple changes in spatial arrangement.” In addition, changing the shape of the rotating portion from a triangular shape to a hexagonal shape (so as to facilitate wrench operation or manual rotation) merely constituted a “simple shape modification” and did not involve any technical difficulty or unexpected effect.
Wisdom Analysis and Suggested Strategies
1. “Structural Definition” in Patent Drafting
The following points should be noted when drafting a specification:
(1) Avoid merely describing functions:
If ASUS intended to emphasize the particularity of “fastening,” the claims should have explicitly incorporated specific structures such as “discontinuous flanges” or “elastic snap-fit mechanisms,” rather than merely using terms such as “fastening portion,” which functionally overlap with “threaded engagement portions.”
(2) Strengthen distinguishing technical effects
It is necessary to demonstrate that effects produced by the structure (such as vibration resistance or automatic positioning) are entirely unachievable by the “screw fastening” disclosed in the prior art.
2. Deployment of “Defensive” Dependent Claims
This case demonstrates that dependent claims directed merely to materials (e.g., plastic) or shapes (e.g., hexagonal shapes) are highly vulnerable during inventive step examination. It is recommended that dependent claims incorporate technical features involving “mechanical interference” or “special operating paths” so as to increase the difficulty of invalidation challenges.
3. Conclusion: Superior Functionality Does Not Necessarily Establish Inventive Step
The IPCC ultimately emphasized that, although the disputed patent improved user experience, the technical means adopted thereby (i.e., the rotary snap-fit structure) merely constituted an “obvious combination and simple modification” of the prior art from a legal perspective. This case reminds developers that the value of a patent lies in “structural innovativeness,” rather than merely “functional convenience.” As “tool-free rapid assembly/disassembly” has already become an industry trend, only deeper mechanical innovation may obtain substantive protection under patent law.
