Jeff Gosling Limited v Autochair Limited
Decision date: 8 July 2025
Neutral citation: [2025] EWHC 1687 (IPEC)
Overall AI summary confidence: high
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: high
This case concerned whether Jeff Gosling Limited's Apex Assist hoist infringed Autochair's patent claiming stepless adjustments. The court held that claim 1 requires both specified adjustments to be stepless, that the Apex Assist's 10mm-stepped upper extension does not literally infringe, that s.60(2) secondary infringement failed because it was obvious fitters would follow the manufacturer's instructions (so the necessary mental element was absent), and that the doctrine of equivalents claim also failed. A declaration of non-infringement was granted to JGL and Autochair's counterclaim failed.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: high
The judgment indicates that where claim language and the specification unambiguously describe an integer as "stepless," claim construction treats that integer as requiring stepless operation; additionally, for s.60(2) secondary infringement a supplier will not be liable where it would have been obvious that the persons who actually put the invention into effect (here, fitters following manufacturer instructions) would not intend to implement the claimed inventive feature, so the requisite mental element is absent.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The judge remarked that an expert's proximity to the industry and potential employer loyalty are factors in assessing weight of evidence but do not automatically outweigh sound technical reasoning from a more generalist expert. The judgment also noted that practical safety considerations may be relevant background facts but do not change claim scope unless the inventive concept expressly includes them.