logo-full-white

Category: Intellectual Property News

Marking the line on innovation patents

A recent Court decision[1] considered an innovation patent relating to passive fire protection and confirmed that, whilst innovative step is low bar, it is a bar that must be cleared for an innovation patent to be valid.

Australia’s 8-year innovation patent is being phased out, but existing innovation patents remain in force and new innovation patent applications can still be filed if they are linked to an Australian non-provisional (or international) patent application filed prior to 26 August 2021.

Generally speaking, an innovation patent is more likely to be valid than a similar standard (20-year) patent because less variation from older technology is required.

Standard patents require an ‘inventive step’ which means ‘non-obvious’ or more than a routine development in the technology, or a plain and logical extension of what is already publicly known.

Innovation patents require an ‘innovative step’ which is a variation that ‘makes a substantial contribution to the working of the invention’. This is a lower bar than an inventive step. Obvious variations of earlier technologies can be valid covered. An early court decision[2] considered spring steel roadside posts and held that each of the following variations separately amounted to an innovative step:

  • a marker hole (e.g. item 135) useful as a depth gauge during installation and a gripping point during removal;
  • a barb (e.g. item 137) for anchoring the post into the ground;
  • a tapered end (e.g. item 132) to make it easier to drive into the ground;
  • lengthwise ribs to resist buckling; and
  • specific dimensions.

In view of this early case law, very few claims (definitions of coverage) have been held invalid for failing to clear the low ‘innovative step’ bar. The recent court decision provides a rare example of technology that was strictly new but lacked an innovative step.

The invention of innovation patent no. 2017101778 relates to a tube that could be mounted under an overhead concrete slab to carry water pipes and electrical cables (etc) from one side of a wall to the other. The tube contains ‘intumescent’ material that swells in response to heat to close the tube to prevent a fire spreading from one side of the wall to the other.

The tube is built in two parts – a first portion 2 and the second portion 4 to make for an easier assembly sequence that includes:

  • attaching the portion 2 to the ceiling;
  • attached the portion 4 to the portion 2 to form the tube; then
  • building the wall about the tube.

The patent includes five claims (definitions of coverage) which each related to a method of constructing a barrier (e.g. a wall). Claim 5 specifies the step of ‘marking a line on the [ceiling] so as to depict the proposed centre line of the [wall]’.

The court held that the tubes and methods were publicly known from earlier conservations except the early method entailed marking out the wall rather than specifically marking out the centre line. The option of using a laser marker to project a line was discussed and the court held that the use of a physical centre line was no more than a trivial addition that did not amount to an innovative step. Claim 5 was held invalid on this basis.

[1] Rakman International Pty Limited v Boss Fire & Safety Pty Ltd [2023] FCAFC 202

[2] Dura-Post (Aust) Pty Ltd v Delnorth Pty Ltd

Mining Safety Patent Fails

Invariably, whenever a patent is enforced, there are two key arguments:

‘infringement’ – the accused will argue that their product and/or process is not covered by the patent; and
‘validity’ – the accused will argue that the patent is invalid.

In recent court decisions [1] concerning mining safety systems, the accused succeeded on both points.

The Invention

Australian patent no. 2019100556 commences with discussion of upwardly drilling bores in the range 20 to 60 metres in length, and the risk of a drill rod breaking and leaving behind 100 to 500 kg of broken drill rod at risk of later falling out.

The patent covers safety systems that rely on wedging action to plug the holes. Two different versions of the safety system are described. The version of Figures 2 and 3 is akin to a masonry anchor. It comprises a Ø100 mm x 8 mm thick steel split-tube 3 fitted to a steel elongate body 6 comprising tapered portion 8. If a broken drill rod falls, it pushes the tapered portion 8 into the sleeve 3 to outwardly drive the sleeve to better engage the bore. Note that the drawings are sideways such that ‘down’ is leftward as drawn.

 

The version of Figure 4 had a different elongate member 6 including tapered portion 9. The tapered portion 9 and the opposite side of the bore B define a downwardly-narrowing gap to trap a falling drill rod.

For the most part, the key components are said to be formed of steel and there is very little discussion of any other material.

The Patent Coverage

As is standard practice, the patent covers more than the specific examples. The patent coverage is defined by the patent’s ‘claims’. Claim 1 was the key claim in this case:

    1. A safety system for protecting against a hazard of drill rod failure in a drilled rock bore above horizontal, and especially a hazard posed by a broken drill rod section within the bore, comprising:

an anchor member [e.g. sleeve 3] configured to be fixed in a proximal end region of the bore adjacent to a rock-face; and

an impact reduction member [e.g. elongate member 6] for reducing an impact of the broken drill rod section striking the anchor member in the proximal end region of the bore, wherein the impact reduction member is configured to be located in the proximal end region of the drilled bore and to extend within the bore above the anchor member to be impacted or struck directly by the broken drill rod section falling within the bore.

Infringement

The accused’s product, sold under the trade mark SafetySpear, performed a similar function and was formed of Nylon 66.

The accused successfully argued that:

  • ‘anchor member’ in claim 1 limited the patent coverage to devices that did not move ‘by more than a de minimis amount of about 5 mm when struck by a falling broken drill bit’ (paragraph 99); and
  • the patentee ‘had not proven that the SafetySpear travelled by no more than 5 mm down the bore when struck by a falling drill rod section’ (paragraph 102).

Validity

Generally speaking, for a patent claim to be valid, the invention defined by the claim must be ‘novel’ (i.e. strictly new) and have an ‘inventive step’. An inventive step requires non-obviousness – that is, something more than a routine development in the technology or a plain and logical extension of what is already publicly known.

Often, novelty and inventive step are prominent amongst the validity arguments. Not so in this case. In this case, the validity arguments focused on the ‘internal’ validity requirements of ‘sufficiency’ and ‘support’.

At least in theory, at the heart of the patent system is a ‘bargain’ – a 20-year monopoly defined by the claims, in return for publishing a comprehensive document (the text and figures of the patent) that teaches the public how to make and use the invention.

The support and sufficiency requirements are intended to ensure that there is a balance between the two halves of this bargain.

The sufficiency requirement is sometimes called the ‘enablement requirement’, and asks whether the patent adequately teaches how to make and use the invention covered by the claims.

The support requirement relates to whether coverage is justified – that is, to whether the claims exceed the inventors’ technical contribution to the relevant area of technology.

In this case, the patent failed on both the support and sufficiency grounds because:

  • the coverage was not limited to any particular material; whilst
  • the description focussed (relevantly only) on steel;
  • the courts
    • accepted the accused’s expert testimony to the effect that there were significant challenges in adopting other plausible materials (such as fibreglass); and in turn
    • ‘found that the skilled addressee would need to exercise inventive skill to come up with ways to address the choice of a suitable material and the correlative task of fashioning the Safety System from that material’ (paragraph 213).

More on patent coverage.

Take Away Points

Whilst the claims will always be critical, this case demonstrates the importance of other aspects of the patent wording. With the benefit of hindsight, the patentee might have won the day if the patent:

  • had explained that the anchor member (e.g. sleeve 3) might only loosely anchor the device in place until the device is struck by a broken drill rod, and some movement is acceptable; and
  • at least briefly mentioned a few plausible materials other than steel.

It also demonstrates the importance of persuasive expert testimony from suitably qualified experts. Judges are experts in applying the law and are (usually) not technical experts themselves. Hence, the role of technical experts can be crucial.

In this case, in relation to the support and sufficiency issues, the accused’s expert was preferred because he had a background in material science. If the patentees had their time again, they may well have been able to rebut the accused’s expert by presenting expert evidence showing that:

  • starting with the information in the patent application, the ‘ordinary non-inventive worker’ could develop versions of the safety system without undue burden; and
  • the inventors’ technical contribution is not limited to steel; and thus
  • the patent satisfies the sufficiency and support requirements.

 

 

[1] concluding with Jusand Nominees Pty Ltd v Rattlejack Innovations Pty Ltd [2023] FCAFC 178

Nail gun patent hits target…even though it’s (arguably) aimed in the opposite direction

Airco have failed in their challenge to an earlier court decision holding that certain Airco fuel cells are covered by Illinois Tool Works’ (ITW’s) Australian patent number 2005232970. The decision highlights the importance of the wording in a patent and that the interpretation of wording can often be argued one way or the other.

Figure 1 of the patent is reproduced below. The patent describes “a second end 62 defining a nipple portion of the valve body 34” (paragraph 26), closure 16 and metering chamber 38.

The coverage of the patent is limited in the following terms:

  1. A fuel cell for use with a combustion tool, comprising:
  2. a housing defining an open end enclosed by a closure;
  3. a main valve stem having an outlet, disposed in operational relationship to said open end and reciprocable relative to said housing at least between a closed position wherein said stem is relatively extended, and an open position wherein said stem is relatively retracted;
  4. a fuel metering valve associated with said main valve stem, including a fuel metering chamber disposed in close proximity to said closure and configured so that when said stem is in said open position only a measured amount of fuel is dispensed through said outlet;
  5. said housing including a separate fuel container,
  6. wherein said fuel metering valve is located within said housing and includes a valve body having a second end opposite said fuel metering chamber located within said container, and (7) wherein the flow of fluid out the outlet of the fuel cell is solely from said separate fuel container.

In Airco’s version of the fuel cell, the metering chamber sits much lower down (see below). Airco argued that its fuel cell did not have the features bolded above. The court disagreed.

 

 

The original judge and all three judges of the appeal court agreed “that the phrase ‘close proximity’ is used to describe the disposition of the fuel metering chamber relative to the closure in the context of the fuel cell as a whole” (paragraph 53) and indeed Airco’s metering chamber is in close proximity to the closure relative to the very bottom of the container shown above.

Likewise, all four judges agreed that “opposite” should be interpreted in the sense that serves to align the features as in the features “facing or across from each other” (paragraphs 29 and 66), so that Airco’s metering chamber is opposite the second end (i.e. the portion to which the label “valve body” points) even though those two things are adjacent to each other and are not at opposite ends of the valve.

Registered design successfully enforced

registered design patent

 

GME has successfully enforced its registered design no. 201613671 to stop Uniden selling the Xtrak microphone. The decision provides an illustrated guide on the types of design changes that will not move a product beyond the reach of an Australian design registration.

Design rights such as design patents guard new products against imitations that look similar. Australian design registrations cover products that are substantially similar in overall impression to the registered design, but how similar is ‘substantially similar’? How closely can the imitator imitate without infringing? The old adage that ‘a picture is worth a thousand words’ is especially true in this context. The key images from the decision are reproduced below.

 

GME’s registered design no. 201613671

 

Uniden’s product

 

Further reading

-> Design registration coverage

-> What is a design registration?

-> What is a patent?

 

A hard stop for two soft-close hinge patents

The patent system is based on a bargain between innovators and the public: private monopoly in return for innovation and information. Newness and non-obviousness are key requirements for a valid standard patent, but they are not the only requirements. This article discusses the sufficiency and support requirements that aim to ensure that the innovation and information justify the monopoly.

Key points

When preparing a patent application, it is important to describe, or at least allude to, multiple versions of the invention and discuss the principles underlying the invention.

You can help your patent attorney prepare a better patent application by providing brief descriptions of alternative versions of your invention.

Background

The coverage of a patent is defined by its “claims”. Generally speaking, a product or process is covered if it has each and every feature specified in a claim. The range of products and/or processes covered by a claim is referred to as an “invention”. The main text and figures of a patent application are called the “specification”. The specification is usually published about 18 months after the initial patent application is filed.

The Australian sufficiency and support requirements were heavily revised in 2013 by amending the legislation to introduce simple language that imported complex meaning from foreign case law.

Sufficiency

The specification must sufficiently describe the invention to enable the ordinary, non-inventive worker (or team) in the relevant industry to make and use the invention without undue burden.

Before 2013, it was enough to enable a single version of the invention. The post-2013 requirement is tougher. It is as important as ever to describe, or at least allude to, multiple versions and to discuss the principles underlying the invention.

The post-2013 legislation explains that the “specification must … disclose the invention in a manner which is clear enough and complete enough for the invention to be performed by a person skilled in the relevant art”. The foreign case law explains that enablement over the whole width of the claim is called for, although this applies only across a relevant range and can be satisfied by a specification disclosing a “principle of general application” corresponding to the terms of the claim.

The decision discussed below explains, by way of example, that the coverage of a patent to “a new non-drip spout for a teapot which is shaped in a special way” does not have to be limited to any particular material because the material is not relevant, e.g. the patent is not invalid just because in theory it covers a teapot that can’t be made because it’s formed of a material that has not yet been invented.

Support

In 2013, the support requirement replaced the old “fair basis” requirement. The old fair basis requirement could usually be satisfied by little more than copying the claims over to another part of the specification for internal consistency.

The post-2013 legislation explains that the claims must be “supported by matter disclosed in the specification”. Case law indicates that the scope of the claims must not be broader than is justified by the extent of the description, drawings and contribution to the art. Whereas the assessment of fair basis was often a rather textual exercise, the assessment of support requires a more practical approach that often overlaps with the assessment of sufficiency.

As the Australian Patent Manual of Practice and Procedure explains:

“An objection for lack of support should be raised where the claims are broad and speculative, in that:

  • the scope of the claims extends beyond the disclosure to encompass possibilities, the effects of which cannot readily be predetermined or assessed on the basis of what is described in the body of the specification; and
  • the description gives merely an indication of the full breadth or scope of the invention, but no, or inadequate, directions of how to put it into practice across the full width of the claims.” (here)

An illustration

A recent Court decision focused on a pair of related patents for hinges for glass-panelled doors, such as for pool fences.

The patented product

 

The patented hinge includes inserts 40, 60 to sit within profiled cut-outs at the edges of the glass panels 500. Insert 40 holds a pair of dampeners 100 to contact faces 64 as the door is closed. Positioning the dampeners in the cut-outs in line with the thickness of the glass reduced the overall thickness of the hinge. The dampeners are orthogonal to the hinge axis, but this orthogonality was not specified in the claims and the patent was held to cover a competitor’s hinge that had parallel dampeners actuated via cams.

The competitor’s product

 

So far so good for the patent holder, but things took a turn for the worse when the Court turned to sufficiency and support.

Whilst the coverage was not limited to orthogonality:

• the specification did not mention any other orientation;
• the Court considered orthogonality to be important because it was tied to the function of contacting the faces 64; and
• expert evidence indicated moving away from orthogonality would require a complete redesign.

The Court reasoned that the “the scope of the invention as disclosed and described [is limited] to a particular hinge mechanism in which the longitudinal dampener axis is more or less orthogonal to the hinge axis”, and went on to conclude that the claims fail on both the sufficiency and support requirements because they cover more than this.

So, the competitor won the day. They will be allowed to continue selling their hinges.

Reflections

This case highlights that when preparing a patent application it is important to describe, or at least allude to, multiple versions of the invention and discuss the principles underlying the invention. In the glare of hindsight, the hinge patents may well have fared better if they had mentioned a parallel dampener version or at least alluded to other potential dampening arrangements.

A practical take-away

You can help your patent attorney prepare a better patent application by providing brief descriptions of alternative versions of your invention. These may well be other design options that you considered and discarded along the way. These alternatives are useful prompts to ensure that the claims cover all that they should, and can be dropped into the specification to support the claims and ensure the invention is sufficiently described.

 

Why patent a manufacturing process?

Q: Why patent a manufacturing process?

A: To guard against price competition.

Some advanced manufacturing processes produce innovative new products. Others make old products more efficiently. In either case:

–       profit margin will disappear over time if imitators can compete on price; and

–       competitors are likely allowed to imitate if you don’t patent.

Generally speaking, in the context of Australian manufacturing, others are free to imitate your new products and processes unless you apply for patent and/or design protection. What’s the difference?

–       patents can cover functional details of new products and processes; and

–       design registrations cover the appearance of new products.

Q: What about foreign competitors?

A: Australian patents are infringed by unauthorised importation.

Australian patents are infringed by unauthorised activities in Australia, e.g. by activities such as making, using, importing and/or selling either a patented product or a product resulting from a patented process. That is…

…an Australian patent covering a manufacturing process can be used to stop competitors importing product that is made overseas using the patented process.

Q: Is my manufacturing process patentable?

A: Almost certainly, if it is new and non-obvious.

Patents have definitions of coverage known as ‘claims’. Generally speaking, a claim is invalid if it covers any technology that was publicly known before the initial patent filing date, or anything that obviously follows on from that old technology. These are key requirements for a valid patent.

If you’re interested in patent protection in a long list of countries, a search for relevant old technologies would be a prudent first step. If Australia is the only country of interest, simply filing a patent application and waiting for the patent examiner’s feedback may well be the better approach.

It’s a mistake to simply assume that your new and valuable developments are not patentable. The non-obviousness threshold is a low bar.

Q: What about software?

A: Many software innovations are patentable.

Much has been written regarding software innovations that are not patentable, even if they are valuable, new and non-obvious. It’s a complex area of law that is evolving as courts hand down more case law.

The key battle lines relate to software that is purely informational in character. Australian courts have held that innovations such as a certain method of calculating a share-price index and a ‘wizard’ to help fill in certain forms are not patentable.

In the context of manufacturing processes, many software changes are clearly on the patentable side of those battle lines. New Zealand’s Patent Examination Manual explains, by way of example, that changing the computer program in a washing machine so the machine gets clothes cleaner and uses less electricity is potentially patentable. Likewise, in the manufacturing context…

…a new and non-obvious software change that, for example, reduces cycle time, uses less material or results in a better product, may well be patentable.

Q: Aren’t patents expensive to enforce?

A: Yes, very.

Going to court to enforce a patent is expensive, even compared to many other matters that you might take to court. On the other hand:

–       if a competitor infringes a valid patent, the competitor is likely to back down before the matter gets to court, to avoid similarly expensive costs in addition to penalties for infringement; and

–       a quality patent may well deter many competitors from producing similar products without any direct cost to you.

Q: Aren’t patents expensive to apply for?

A: Yes and no.

Patenting a mechanical invention in Australia might entail an initial cost in the ballpark of $6K and a total investment over the entire 20-year life of the patent in the ballpark of $35K. Any patent attorney worth their salt would be pleased to have a preliminary discussion without charge to talk through your invention, your prospects of success and the applicable costs.

Q: But patenting takes years?

A: Yes, but you can use the process within a few weeks.

If you can supply your patent attorney with a quality description of your invention, your initial patent application should be filed within a few weeks. Once the application is filed, you can go public with (and/or commercially use) the invention without harming your patent rights in what you have invented to that point. Australia has a 12-month grace period that can excuse premature publication and/or use, but it’s best not to rely on the grace period.

Following the ordinary process, your Australian patent application will be examined in due course and, if you are successful, a patent will be granted on the application perhaps four or five years after the initial filing. It’s usual to let the process take this long, to defer costs amongst other advantages.

If at some point during those four or five years there was an infringement, you could accelerate the process which, all going well, would lead to a granted patent within eight months or so.

 

How to read a patent

Patent documents are typically dense with technical information and often include long sections of strange wording far removed from everyday English. Finding what you need is much easier once you learn your way around a typical patent document and understand the logic behind the strange wording.

Anatomy of a patent document

The text and drawings of a patent (or patent application) are known as the patent specification. Usually, the text is divided into sections with headings such as Abstract, Field of the Invention, Background to the Invention, Summary of the Invention, Brief Description of the Drawings, and Detailed Description of the Embodiments.

Abstract

The abstract is usually a single paragraph that should give a general indication of what the patent is about. Sometimes the abstract includes wording closely tied to the strange wording of the claims. If the abstract is hard work, it’s often best to skip over it.

Field of the Invention

This is usually a short sentence or two indicating the type of technology that the invention is relevant to. Historically, Patent Offices have relied on this section to allocate patent applications to patent examiners with the relevant technical background.

Background to the Invention

Most patent documents include some sort of summary of similar technologies that were publicly known before the initial patent application was filed. Usually, the Background is one of the easier sections to read and provides a context that helps to make sense of the rest of the document.

Summary of the Invention

Sometimes the Summary will start with a paragraph or two that provides great insight. Otherwise, the Summary can be especially hard work and is often best skipped over on the first read of the patent document.

Often the Summary is almost a cut-and-paste of the strange wording of the claims (below) to help ensure that the invention specified in the claims is consistent with what’s described outside of the claims.

Brief Description of the Drawings

This section usually includes a separate one-line description for each of the drawings, e.g. ‘Figure 1 is a perspective view of a mounting assembly’.

It’s often best to skip over this section on the first read of the document, but the Brief Description can be very useful when assessing how certain terms are used in the patent document as ‘ah, so the thing in Figure 1 is what they mean by mounting assembly’.

Detailed Description of the Embodiments

This section is usually an easier read than the Summary and serves to describe embodiments (examples) of the invention. Typically, different features will have reference numerals showing where those features can be found in the drawings.

Claims

The claims are critical because they define the coverage of the patent or patent application. Professional advice is strongly recommended when assessing patent coverage.

Often there will be a mix of:

  • independent claims that define the outer bounds of coverage, and
  • dependent claims that refer back to the independent claims.

Generally speaking, to infringe a patent, each and every feature of an independent claim must be taken, although:

  • there are some exceptions,
  • claims can be amended,
  • it’s always prudent to check for closely related patents, and
  • claim interpretation is not always straightforward.

To be valid, the claims must meet a range of legal requirements. Meeting these requirements whilst providing commercially effective patent coverage leads to strange wording far removed from everyday English. By way of example, whereas in everyday English you might say ‘two parts bolted together’, a patent claim might say ‘two portions fixed relative to each other’ to cover off (e.g.) the parts being riveted or welded, or simply formed as two portions of a single piece of metal.

Usually, the claims are not limited to the examples described in the text and/or shown in the drawings – continuing the example above, a claim that mentions a ‘mounting assembly’ likely covers products that have mounting assemblies that do not necessarily resemble what’s shown in Figure 1.

How to read a patent

Step 1 – Very briefly skim the document to get a general sense of what it’s about

The drawings and Background, and sometimes the first paragraph or two of the Summary are often good starting points.

Step 2 – Decide why you are reading the patent

Do you need to know what’s covered? Or, are you interested in learning about the technology that’s described in the patent document?

Step 3 – Assessing coverage – Read the independent claims

If you need to know what’s covered, locate the independent claim(s), that is the claims that don’t refer to any other claims.

As above:

  • generally speaking, to infringe a patent, each and every feature of an independent claim must be taken, although
  • professional advice is strongly recommended when assessing patent coverage.

Step 4 – Understanding the technology – Read the Detailed Description of the Embodiments

Reading the Detailed Description and following the reference numerals to the drawings is usually the best way to understand the technology described in the patent document. It’s often useful to start with the Detailed Description before going back to the Summary and the claims.

Best wishes for a safe and happy New Year!

Our office will close for the holidays midday Friday 24 December 2021 and will reopen on Tuesday 4 January 2022.

We are available for urgent matters between these dates. If you have an urgent enquiry during this time, please forward an email to mail@brmpatentattorneys.com.au and we will respond as soon as we can.

Best wishes for a safe and happy New Year!

A 12-month grace period for Australian design registrations

In Australia we have ‘design registrations’ which are akin to design patents in the US and ‘patents’ which are akin to utility patents in the US. A general 12-month grace period has long applied in connection with Australian patents whereas there is no similar grace period in connection with Australian design registrations. Prematurely publishing a design can immediately lead to a loss of design rights.

The situation is about to change. A 12-month grace period will soon be introduced. As of 10 March 2022, design owners who prematurely publish their designs may secure valid design protection by applying for design protection within 12-months of the first publication. The new provision is here.

The new grace period for designs will differ from the grace period for patents in that publications (not earlier than 10 March 2022) in the 12 months leading up to the priority date will be excused. As such, valid Australian design protection may be secured by filing a foreign design application within 12-months of a publication then filing an Australian design application within the following 6 months (and along with a claim to priority from the foreign design application). In contrast, the grace period for patents excuses publications in the 12 months leading up to the first Australian non-provisional filing date.

The new grace period for designs is framed in generous terms to excuse more than premature disclosures of identical designs. It excuses ‘publication or use of a design (which may or may not be the subject design)’ by a party connected to the registered owner. On the other hand, it does not excuse disclosures by foreign Designs Offices (and similar organisations); such disclosures are explicitly carved out of the new grace period.

Despite the generous terms of the new grace period, we recommend viewing the new grace period as a back up in case of error rather than something to be relied upon as a matter of course. The new grace period will not assist (i.e. rights will be lost) if others independently create and publish similar designs before design protection is applied for.

Welcome to BRM Patent Attorneys

BRM is a new firm with a long history. BRM’s experienced professionals together have well over a century of experience providing outstanding patent attorney services.

Some of you may know our professionals from Wadeson. In 2019, Wadeson celebrated its 10th anniversary as a proudly independent Australian patent and trade mark attorney firm. As of 1 July 2021, Wadeson’s patent team commenced trading as BRM1 and Wadeson2 is focusing solely on trade marks.

We look forward to working with you.

 

1 BRM Patent Attorneys Pty Ltd; ACN 649 973 204
2 Wadeson IP Pty Ltd; ACN 623 567 760