Interference No. 103,146
proof of conception, the rule does not dispense with the
requirement of some evidence of independent corroboration.
See Coleman, 754 F.2d at 360, 224 USPQ at 862. As the CCPA
stated in Reese v. Hurst, 661 F.2d 1222, 1225, 211 USPQ 936,
940 (CCPA 1981): "[the] adoption of the 'rule of reason' has
not altered the requirement that evidence of corroboration
must not depend solely on the inventor himself." There must
be evidence independent from the inventor corroborating the
conception.
The purpose for requiring some form of corroboration
is to prevent fraud. The full discovery now available in
interferences may be better able to root out fraud, but it is
nevertheless clear that not all frauds will be discovered.
Nor can such discovery substantially replace the protection
against fraud that the long-standing rule of independent
corroboration provides. Reese, 661 F.2d at 1226 n.4, 211 USPQ
at 940 n.4.
Additionally, we acknowledge that there is no single
formula that must be followed in proving corroboration. An
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