Supplementary Protection Certificate (SPC) for combination products: 'Protection of incremental inventions” in pharmaceutical field after Court of Justice of European Union (CJEU) ruling in Actavis case.

Name of relevant case: Actavis Group PTC EHF, Actavis UK Ltd V Boehringer Ingelheim Pharma Gmbh & Co. Kg, (C-577/13) Single Sentence Summary: In Actavis case, CJEU held that multiple Supplementary Protection Certificates (SPCs) are not possible relying on single basic patent wherein Article 3 (a) and (c) provisions are not met. But this ruling posed difficulties to Innovators as to how to protect the incremental inventions or add-on inventions.