Japanese patent practice applies “Product Identity Theory” as Product-By-Process claim.

The Supreme Court says, “Even in the case of what is generally referred to as a “product-by-process claim,” that is, when a claim of a patent for an invention of a product recites the manufacturing process of the product, the technical scope of the patented invention should be determined as referring to products that have the same structure, characteristics, etc. as those of the product manufactured by the manufacturing process recited in the claim.” (2012 (Ju) 1204)