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Vapor Canada Limited (Plaintiff) v.
John A. MacDonald, Railquip Enterprises Limit ed, and Vapor Corporation (Defendants)
No. 1
Trial Division, Walsh J.—Ottawa, August 19, November 25, 1971.
Pleadings—Averments in statement of claim—Infringe- ment of patent and trade mark—Disclosure of trade secret— Insufficient details—Striking out.
Averments in a statement of claim that the defendants infringed plaintiff's patent and trade mark, that the defend ant M disclosed the plaintiff's trade secret, and that the defendants engaged in improper business practices are too imprecise and will be struck out. The details of the patent, trade mark and trade secret, the manner of infringement of the patent and trade mark and the persons to whom the trade secrets were disclosed should all be disclosed.
A prayer for delivery up by the defendants of all infring ing articles will be struck out as too imprecise.
Dow Chemical Co. v. Kayson Plastics & Chemicals Ltd. [1967] 1 Ex.C.R. 71; Precision Metalsmiths Inc. v. Cercast Inc. [1967] 1 Ex.C.R. 214; Union Carbide Canada Ltd. v. Canadian Industries Ltd. [1969] 2 Ex.C.R. 422; Hassenfeld Bros. Inc. v. Parkdale Novelty Co. [1967] 1 Ex.C.R. 277, referred to.
Redmond Qua in for plaintiff.
J. Nelson Landry for defendants.
WALSH J.—Defendants move for striking out plaintiff's statement of claim and amended statement of claim filed on August 11, 1971 and November 3, 1971 respectively on the ground that it discloses no reasonable cause of action, it is vexatious and may prejudice, embarrass or delay the fair trial of the action. On November 9, 1971, a further amended statement of claim was filed by plaintiff, making some very minor amendments to the amended statement of claim of November 3, 1971 and by agreement of counsel at the hearing before me on defendants' motion, the judgment will deal with this further amended statement of claim.
A brief summary of the background of these proceedings as disclosed by the court record and by counsel in argument before me is rele-
vant. The original statement of claim which accompanied a notice of motion for an inter locutory injunction was based on alleged patent infringement, unfair competition, and a disclo sure of trade secrets and confidential informa tion by defendants, John A. MacDonald and Railquip Enterprises Ltd., the third defendant, Vapor Corporation, against whom no relief is sought, having been joined as patentee of cer tain of the patents pursuant to section 57(2) of the Patent Act. The further amended statement of claim added paragraphs specifically alleging trade mark and copyright infringements on the part of the said defendants to the patent infringement, unfair competition, disclosure of trade secrets and of confidential information alleged in the original statement of claim. Since the defendants have not yet pleaded to the proceedings, the amended statement of claim and further amended statement of claim by plaintiff can be made by virtue of Rule 421 without leave, and even if leave had been required under Rule 424, it would have been granted by virtue of Rule 427 notwithstanding that it might perhaps be argued that it added new causes of action, since these clearly arose out of the same facts or substantially the same facts as those in respect of which relief had already been claimed in the original statement of claim.
In support of its application for an interlocu tory injunction plaintiff, in due course, submit ted three affidavits in response to which defendants allegedly submitted nine. affidavits. Lengthy cross-examinations have taken place which are not yet completed of the various witnesses in connection with these affidavits and counsel informed the court that the tran script of these examinations already amounts to some 3,000 pages. As a result, the application for interlocutory injunction has not yet been dealt with. In view of defendants' failure to plead to the original statement of claim, plaintiff made an application for judgment by default pursuant to Rule 437, which application was dismissed by Gibson J. on October 14, 1971 with costs in favour of defendants in any event of the cause.
In argument before me plaintiff's counsel relied strongly on the fact that defendants' motion was only made on November 10, 1971, nearly three months after the date the original statement of claim was filed and served on defendants, stating that the original statement of claim was less complete and detailed than the amended statement of claim and further amend ed statement of claim, and that if defendants had proposed to object to the statement of claim on the ground that it discloses no reasona ble cause of action, is vexatious and may preju dice, embarrass or delay the fair trial of the action, this should have been done at that time, and that defendants should not be permitted to do so and further delay the progress of the action by making this motion now. I can find no support for this argument in the rules nor was any jurisprudence cited to me that could sup port it. Plaintiff, itself, by filing an amended statement of claim as late as November 3, 1971 and further amended statement of claim on November 9, 1971, as it was entitled to do under the rules respecting amendments, opened the door to defendants' motion and, in any event, the rules set out no delay within which defendants were obliged to make it, Rule 419 permitting the court "at any stage of the action" to order any pleading or anything in it to be struck out with or without leave to amend. Moreover, the present motion, if granted, while it may delay the progress of the action itself, does not have the effect of delaying a hearing on the motion for interlocutory injunction which cannot be proceeded with until the cross- examination of defendants' witnesses has been completed by plaintiff's attorney.
Coming now to the merits of defendants' motion, I find that the plaintiff's further amend ed statement of claim is defective in many respects in accordance with the jurisprudence of this Court established recently in a series of cases including Dow Chemical Co. v. Kayson Plastics & Chemicals Ltd. [1967] 1 Ex.C.R. 71; Precision Metalsmiths Inc. v. Cercast Inc. [1967] 1 Ex.C.R. 214, which judgments of Jack- ett P, as he then was, were followed by Thurlow J. in Union Carbide Canada Ltd. v. Canadian Industries Ltd. [1969] 2 Ex.C.R. 422, and more recently in an as yet unreported judgment of
Pratte J. in Posting Equipment Corp. v. B & F Metal Works Ltd. T-2286-71, August 4, 1971, all of which were patent infringement actions. The same principles were applied to industrial design and trade mark infringements by Noël J, as he then was, in Hassenfeld Bros. Inc. v. Parkdale Novelty Co. [1967] 1 Ex.C.R. 277, and his as yet unreported judgment in Lovable Brassiere Co. of Canada Ltd. v. Lovable Knits Inc. B-4229, April 1, 1971.
I quote from these judgments to illustrate the principles of proper pleadings in industrial prop erty cases which they have established. In the Dow Chemical case President Jackett stated at page 75:
... A bare assertion that the defendant has infringed the plaintiff's rights is not an allegation of facts constituting a cause of action and a statement of claim in which that is the only assertion of infringement could be struck out as being an abuse of the process of the Court. See Marsden v. Albrecht (1910) 27 R.P.C. 785 (C.A.) per Buckley L.J. at pages 788-9. The facts must be alleged in such a way that the Court can be satisfied that, assuming the truth of what is alleged, the plaintiff has an arguable cause of action (Phi- lipps v. Philipps, (1878) 4 Q.B.D. 127). It would be no answer to an application to strike out in such a case for the plaintiff to say that, if he is allowed to have unrestricted discovery of the defendant, he may then be in a position to plead a cause of action.
This judgment is also authority for the proposi tion that a plaintiff cannot give particulars respecting one particular breach of which he complains and then add allegations of a vague nature respecting other breaches which he sus pects but of which he is not definitely aware. At page 73 the judgment states:
Counsel for the plaintiff takes the position, in effect, that the plaintiff, if it has information of one type of infringe ment of its patent, is entitled to launch proceedings for infringements of that type and for anything else that the defendant may have done that constitutes infringement of the same patent, so that he will be in a position, in the course of obtaining discovery from the defendant, to explore the possibility of there having in fact been types of infringement of which he did not know when he launched his action. He concedes that, some time before trial, he must, if the defendant then insists, amend his Statement of Particulars by adding allegations of any other infringements of which he has become aware in the meantime and upon which he proposes to rely, so that he will then be restricted at trial to his Statement of Particulars as amended.
On commenting on this contention, the judg ment states at page 74:
It may well be, of course, that the plaintiff, at the time that an action is instituted, has grounds for asserting that the defendant has done certain things although he is not in a position to say precisely when or where or how the defend ant did such things. These details in the circumstances of a particular case may be entirely within the knowledge of the defendant. For example, the plaintiff may be in a position to show that a manufacturer sold a certain class of goods that had been manufactured by his patented process. Only the defendant can know, however, when and where they were so manufactured. (In such a case, it obviously would not be necessary for the plaintiff to give such particulars, at least before discovery had taken place. There may also be cir cumstances in which the plaintiff's knowledge is sufficient to warrant commencing proceedings but it is appropriate to give him an order for inspection of the subject matter of the action under Rule 148A before he is required to settle his Particulars of Breaches. Compare Edler v. Victoria Press Manufacturing Company (1910) 27 R.P.C. 114.
The judgment further states at page 78:
In my view, however, none of these problems arise when the plaintiff, in addition to particularizing as to the facts constituting an infringement that are known to him, attempts to bring within the ambit of his Statement of Claim facts that are unknown to him and which, as far as he has any ground for belief, do not exist. Such an attempt to include in a Statement of Claim causes of action based upon no known facts must fail. Either the plaintiff can show that there are facts that justify including a second cause of action in the Statement of Claim or the references to such a possible cause of action are not relevant to any cause of action and should be struck from the pleading.
These principles are again set out by President Jackett in the Precision Metalsmiths case, which referred to the Dow Chemical case. At page 220 he states:
In an action for infringement of a patent under the Patent Act, there must therefore be in the Statement of Claim allegations
(a) of facts from which it follows as a matter of law that the plaintiff has, by virtue of the Patent Act, the exclusive right to do certain specified things, and
(b) that the defendant has done one or more of the specified things that the plaintiff has the exclusive right to do.
It is not a compliance with the requirement that the material facts be alleged merely to state the conclusions that the Court will be asked to draw, which are
(a) that the plaintiff is the owner of one or more specified Canadian patents, and
(b) that the defendant has infringed the plaintiff's rights under such patents.
The principles set out in these two cases were carried a step further by Thurlow J. in the Union Carbide case in which, despite the fact that particulars of breaches indicated which specific paragraphs of the patents in question had allegedly been infringed, he held that this was insufficient, stating, at page 425:
... in a case where interference with a property right is to be the basis for the relief sought, a concise description of the right asserted with a statement of the facts as to how the right arose. What is required, moreover, is not a reference to where information as to the plaintiff's right can be found but a concise description of it sufficient to point unequivo cally to what it is that the defendant has violated.
Again, at page 427, he states:
... I should add, however, that in many, if not most cases the description of the right asserted by setting out a number of lengthy and largely unintelligible patent claims, while perhaps not so susceptible to the objection that no cause of action is disclosed might well be open to the objection that it was not a concise statement of a material fact and might be just as objectionable and liable to be struck under paragraphs (c) and (e) of Rule 114 as being likely to preju dice and embarrass the fair trial of the action or as being an abuse of the process of the Court. As I see it what is required is a succinct description, stripped of all unneces sary and irrelevant verbiage, of the essential feature which the defendant is to be alleged to have taken. To compose such a description may require time and effort but, as I see it, a plaintiff and his counsel should know before the action is commenced what the particular right is that they propose to prove has been infringed and should, be able tocompose a sufficient description of it. ,
In applying the same principles to industrial design in the, Hassenfeld Bros. case, Noël J., now Associate Chief Justice, referred to the Precision Metalsmiths case and stated at page 281:
... The allegation of infringement contained in the state ment of claim that the defendant "by reason of its importa tion, distribution and sale of its `Johnny Canuck Canada's Fighting Soldier Fully Jointed Move Into 1001 Positions' doll ... has infringed the plaintiff, Hassenfeld Bros., Inc.'s industrial design registration No. 204, folio 26805" is not sufficient as this allegation does not contain such a descrip tion of the design or alleged fraudulent imitation thereof that the defendant is alleged to have imported, distributed and sold, as will show that they are in fact an infringement of the plaintiffs' rights. In the absence of such a description, there is, therefore, no allegation of the material facts neces sary to show a cause of action for infringement.
In the Dow Chemical case President Jackett was dealing with a motion for particulars although, as he pointed out, the objections to the form of the pleading might well have been made by means of a motion to strike. In the present case, we have the converse situation. Defendants have made a motion to strike and while substantially similar results might have been obtained, certainly with respect to some of the improperly drawn paragraphs of the further amended statement of claim, by a motion for particulars, the motion they have brought is perfectly proper. There would seem to be no practical advantage, and on the contrary, the proceedings on the merits would be further delayed, if only those paragraphs which are manifestly improperly drawn were struck, leav ing in others with respect to which a motion for particulars would subsequently have to be made, so it is my intention to strike out all paragraphs which appear to me to require fur ther clarification, reserving the plaintiff's right to apply for leave to substitute other pleadings for those so struck out.
Dealing now with specific paragraphs of plaintiff's further amended statement of claim, paragraphs 3 and 4 read as follows:
3. Defendants MacDonald and Railquip Enterprises (herein called the defendants) have infringed said patents at the times and places set forth in the particulars of breaches delivered herewith, by making, constructing, using and vending to others in Canada the inventions set forth in said letters patent, or causing them to be.
4. The infringement consists of infringement of every claim in the said letters patent and every element of the combinations respectively set forth in each of the claims, by using (1) in some products the identical combinations and identical elements and (2) in other products, unsubstantial variations thereof.
and the particulars of breaches referred to in paragraph 3 reads:
1. The Defendants (other than Vapor Corporation) at various dates in 1971 at present unknown to the Plaintiff infringed the Patents (in respect of every claim and in respect of every element of every claim) set forth in the Statement of Claim and specifically on or about the 30th April, 1971, by making, constructing, using and vending to others to be used, the said inventions and specifically the Defendants sold 150 Heaters to the National Steel Car
Company Limited at Hamilton (for installation in box cars of Canadian National Railways) which infringed Patent No. 774,371 and the other Patents referred to, at Hamilton, Montreal and at other places at present unknown to plaintiff.
These paragraphs and the particulars in ques tion in effect charge defendants with infringing every claim in plaintiff's patent in the heaters they have sold to National Steel Car Company and are too vague, giving no succinct descrip tion of the patents or portion of the patents which have allegedly been infringed, nor the manner in which defendants' heaters have infringed them, and should be struck.
Paragraphs 7 and 7.A.1 read as follows:
7. MacDonald, as Vice President of the plaintiff, dis closed to others, for his own benefit, and contrary to his written agreement with the Plaintiff, certain trade secrets in contravention of the laws to that effect and engaged in that business practice and other business practices, contrary to honest industrial and commercial usage in Canada, as set forth in this pleading.
7.A.1. The plaintiff is the first, and present, owner of copyright in several hundred manufacturing and other draw ings, and specifications, and other things which the defend ants fraudulently took (or caused to be taken) from the premises of the plaintiff the precise number, and descrip tions, and dates, of which are at present unknown to the plaintiff but known to the defendants.
These paragraphs give no details of the trade secrets which defendant, MacDonald, allegedly disclosed to others, nor to whom he disclosed them, nor what specific copyrighted manufac turing and other drawings, specifications and other things he allegedly took, and should be struck.
Paragraph 8 reads as follows:
8. The defendants have infringed in Canada plaintiff's trade mark, "Scotch Guard" as applied to railway box car heaters, (which the plaintiff has used for at least 15 years to distinguish such heaters made by it from any that might be made by others and which defendant MacDonald himself, while an employee of the plaintiff, has so used) since February, 1971 by the use of that name in respect of box car heaters, and by selling, distributing and advertising box car heaters in association with that name.
but no specific details are given as to the use of the name "Scotch Guard" by defendants nor of the selling, distributing, and advertising of the heaters in association with that name, which is alleged. It should also therefore be struck.
Paragraph 10 reads as follows:
10. The Defendants pursuant to an illegal plan made tenders slightly under those of the Plaintiff for work to be done that necessarily involved use of the confidential infor mation, copyrights, trade mark, trade secrets and patents above referred to.
This paragraph gives no details as to what con fidential information, copyrights, trade mark, trade secrets and patents belonging to plaintiff were necessarily involved in the work to be done which was the subject of the said tenders. It should therefore be struck.
Paragraph 15 reads as follows:
15. MacDonald, while in the employ of the Plaintiff, up to the end of April, 1971, always recognized as valid the patents being infringed by him in the construction of the items in respect of which he has now made competing bids with the Plaintiff and in fact declared to others, on behalf of the Plaintiff, that such patents were valid.
but gives no details as to the patents allegedly being infringed by MacDonald. It should be struck.
Paragraph 17 reads as follows:
17. The Defendants or one of them has applied for a patent on items practically identical with the inventions set forth in the said patents subject to minor deviations and thus recognizes the validity of the above patents.
but gives no details as to the alleged patent application of defendants nor in what respect it is practically identical with the inventions set forth in plaintiff's patents, nor which of plain tiff's patents is involved. It should also be struck.
Paragraphs 22 and 23 read as follows:
22. MacDonald took things belonging to the Plaintiff and parts and descriptions thereof, as well as plans to be used
by obliterating the name of the Plaintiff but retaining the Part Numbers of the Plaintiff.
23. MacDonald and Railquip, unknown to the Plaintiff, illegally took from the Plaintiff's plant and kept at the office of Railquip at 11387 Gouin Boulevard West, Roxboro, Quebec, nearly 200 plans, specifications and letters belong ing to the Plaintiff and on 15th July, 1971 had them there.
but do not specify what things, parts and descriptions, plans, specifications and letters belonging to plaintiff were taken by MacDonald and Railquip and should therefore be struck.
Paragraph 27 reads as follows:
27. In the interval between his being approached by MacDonald and his finally rejecting MacDonald's efforts, James gave to MacDonald certain papers that James had in his possession, the details of all of which are not at present known to the Plaintiff.
This is too indefinite and should be struck. Paragraph 30 reads as follows:
30. Since the 30th April, 1971, Defendants have by under-bidding Plaintiff, sold 150 box car heaters to National Steel Car (a builder of box cars for the Canadian National Railways) which infringe Patent No. 774,371 and the other patents referred to for $90,000 and other items based on trade secrets and other confidential information of Plaintiff for a total of around $260,000 as compared with Plaintiff's bid of $289,000. MacDonald had while an employee, assist ed in preparing the Plaintiff's secret bid.
but in referring to "Patent No. 774,371 and the other patents referred to" and also referring to "other items based on trade secrets and other confidential information" it gives no details as to the nature of the patent claims which have been infringed, nor what other items have allegedly been so sold, nor what trade secrets or confidential information of plaintiff was used. It should therefore be struck.
Paragraph 32 reads as follows:
32. The patents infringed were issued to Vapor Corpora tion and duly assigned by it to the Plaintiff and are:—
(1) 621,537 dated the 6th June, 1961 on application dated the 22nd September, 1958, assigned by assignment regis tered as No. 540,140.
(2) 774,371 dated 26th December, 1967, on application dated the 3rd June, 1966, assigned by assignment registered as No. 814,857.
(3) 784,491 dated 7th May, 1968 on application dated 24th October, 1966, assigned by assignment registered as No. 818,858.
and, as this merely refers to the patents and gives no succinct description of them or the parts of them which have allegedly been infringed, it must be struck.
Paragraphs (d), (e) and (f) of the conclusion setting out plaintiff's claims read as follows:
(d) Delivery up to it of all products now in the possession or under the control of the Defendants, their officers, servants or agents, that are the combinations set forth in the claims of the said patents or that are elements of such combinations.
(e) Delivery up to it of all products now in the possession or under the control of the Defendants, their officers, servants or agents in the making of which the knowledge or information, or drawings, or parts (and other confiden tial information or things) obtained by MacDonald while in the employ of plaintiff was used.
(f) Delivery up to it of plans, drawings, specifications, parts, or letters referred to above now in the possession or under the control of the Defendants, their officers, servants, or agents.
These are too imprecise in their references to information, drawings, parts, plans, specifica tions, letters and confidential information and should be struck.
In making this ruling I am not unmindful of the difficulty for plaintiff in requiring it to be specific at the time of the commencement of its action as to precisely which of its patents, drawings, plans, specifications and so forth were used by defendants in their manufacture and sale of the heater complained of. This dif ficulty was touched on by President Jackett in one of the passages I have cited from the Dow Chemical case (supra). However, extensive dis covery has now taken place, although not yet fully completed, and a model of the heater alleged by defendants to be that which they are manufacturing has been produced as an exhibit, so that plaintiff's agents and employees have
now had an opportunity of examining it in detail. Plaintiff should be well aware at this stage of the proceedings and capable of stating with some precision which of its patents, draw ings, plans and specifications defendant Mac- Donald allegedly took with him or copied when he left its employ, and which of these defendant Railquip Enterprises Ltd. has used in the con struction of this heater. The fact that defend ants themselves have all this information in their possession does not relieve plaintiff of the burden of alleging with precision which of the patents, plans, specifications, drawings, trade secrets and other items complained of defend ants have used or are using. Defendant Mac- Donald had a right after leaving plaintiff's employ to enter into competition with it, and a distinction will have to be made at the trial between his use of his general knowledge in this field, which is his personal property as are any original plans, drawings, specifications and so forth which he made subsequent to his employ ment by plaintiff, and any use which he or Railquip may have made of plans, drawings and specifications in which plaintiff has the copy right, or objects or processes for which plaintiff has the patent. At this stage of the proceedings plaintiff should have sufficient information to enable it to plead precise allegations of fact giving rise to the right claimed instead of making vague and generalized allegations which it hopes will cover infringements which it may have overlooked or of which it is not at this time aware.
I therefore order as follows:
1. That paragraphs 3, 4, 7, 7.A.1., 8, 10, 15, 17, 22, 23, 27, 30 and 32 of the further amend ed statement of claim be struck out, as well as the further amended particulars of breaches, and paragraphs (d), (e) and (f) of the conclu sions of plaintiff's amended statement of claim.
2. That the plaintiff, however, be granted leave to apply for leave to substitute other pleadings for the further amended statement of claim and particulars of breaches that are so struck out.
3. That if no such application be made within four weeks from the date of this order or such other delay as the Court may on application allow, the defendants may apply to have this action dismissed.
4. That the costs of this application to strike out be in favour of defendants in any event of the cause.
Rule 114(1)(c) and (e) referred to in this judgment read as follows:
114. (1) The Court may at any stage of the proceedings order to be struck out or amended any pleading or anything in any pleading on the ground that
(c) it may prejudice, embarrass or delay the fair trial of the action,
(e) it is otherwise an abuse of the process of the Court;
Rule 419 of the present Rules contains substantially similar provisions.
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