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In this August 2019 edition...

Indian Intellectual Property Appellate Board

Doctrine of necessity invoked by Delhi High Court to make non-functional Intellectual Property Appellate Board (IPAB) operational!

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Indian Patent Office Publishes Draft Patent (Amendment) Rules

The Indian Patent Office (IPO) published Draft Patent (Amendment) Rules, 2019 on 1 June 2019 and asked for submission of comments and/or suggestions by stakeholders within one month of publication of such draft Rules.

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[Image: CIPC]

South Africa – Anticipated Increase in Official Fees for Patents and Designs

Earlier in 2019, the Companies and Intellectual Property Commission (CIPC) indicated that official fees for South African patents and designs were to be increased.  In addition, a distinction was in future to be drawn between small and large entities, insofar as the filing and renewal of patents and designs are concerned. Implementation is currently earmarked for 1 October 2019, although that could change.  

It is understood that the official fees for patent & design applications, and for corresponding renewals, will increase significantly insofar as large entities are concerned.  In addition, a general 5% official fee increase will be applied to all other official fees, and provision is to be made for a regular annual increase of 5% going forward.  It is believed (at this stage at any rate) that it may be preferable to pay official fees at the large entity rate unless one is absolutely certain that the patentee qualifies for the lower rate.

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[Image: EPO Logo]

New Rules of Procedure of the EPO Boards of Appeal from 1 January 2020

Doctrine of necessity invoked by Delhi High Court to make non-functional Intellectual Property Appellate Board (IPAB) operational!

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[Image: Sharon E. Crane]

FICPI CET5 Addresses Arising Issues in the Biotechnology and Pharmaceutical Fields

FICPI CET5 includes members from 18 countries, who monitor, report on, and make recommendations for positions on the protection of intellectual property in the biotechnology and pharmaceutical fields.  CET5 is currently active in studying 3D printing, artificial intelligence, biodiversity, traditional cultural expressions and genetic resources, the prior art effect of virtual compounds, patentability of antibodies and polymorphs, issues relating to supplementary protection certificates and subject matter eligibility.

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News in 2019

If you have country or regional news that needs sharing with the FICPI membership,
please use the FICPI Publication form available here.

We look forward to hearing from you!

Indian Intellectual Property Appellate Board

The Delhi High Court taking cognizance of the colossal pendency of cases before the IPAB and its perennial non-functioning hold the view that the doctrine of necessity has to be invoked in this case. The Court observed that legislative intent is of the continuity of IPAB and not its cessation because of a vacancy in its technical membership. It clarified that even if the post of the Technical Member is lying vacant, the IPAB can proceed to hear the urgent matters and the orders passed would not suffer invalidity on the ground of lack of Coram.

In Mylan Laboratories Limited Vs Union Of India & Ors W.P.(C) 5571/2019 & C.M. Appln. 24540/2019 & 26833/2019, the Delhi High Court took cognisance of non-functioning of the IPAB for a very long time and directed the Deputy Registrar of Intellectual Property Appellate Board (IPAB) to file the status report with respect to the vacancy in position of the Technical Members of IPAB. In this case, the petitioner approached the Court for an urgent hearing on a stay application, since the IPAB - before which an appeal against the order of the Controller to dismiss a pre-grant opposition along with a stay application was filed - was non-functional in the absence of Technical Member (Patents) since 04th May, 2016.

In accordance with the Court order, the Deputy Registrar of the IPAB handed over a status report through personal presence at the Court hearing on May 24, 2019.  Following is the summary of the report of pendency at the IPAB in view of its non-functioning or inadequate functioning: 

Details of Pending Cases

S.No.

Subject of Cases

No. of Cases Pending as on 23/05/2019

1.

Trade Mark

2626

2.

Patent

617

3.

Geographical Indication

01

4.

Copyright

 691

Furthermore, as per the status report, no Technical Member (Copyright) has been appointed till date. With respect to Patents, the post of Technical Member (Patents) is lying vacant since May 4, 2016. With respect to Trade Marks, the post of Technical Member (Trade Marks) is lying vacant since December 5, 2018. In addition, there is only one Technical Member relating to Plant Varieties Protection.

It was observed that the Intellectual Property Appellate Board (IPAB) was created since there was a need for an expert body to adjudicate issues that are technical in nature. This is more so in case of special legislation such as Patents Act, 1970 and the Protection of Plant Varieties and Farmers' Right Act, 2001. However, for various reasons, the true objectives of establishing the IPAB has not been successfully achieved, leading to denial of justice.

It was argued that the major reason for the current crisis of pendency and non-functioning of the IPAB is owing to vacancies not being filled up. The other major reason for the high pendency and the non-functioning of the IPAB is owing to the stringent condition in Section 84 of the Trade Marks Act, 1999. Section 84(2) of the Act inter-alia states that a Bench of the IPAB “shall” consist of one Judicial Member and one Technical Member. Thus, as a corollary this Section makes it imperative for an appeal to the IPAB to be heard by a Bench of at least two members. Section 84 makes it virtually impossible for the IPAB to dispose of cases in the absence of the required Coram, as is the case presently.

The Court taking cognizance of the colossal pendency of cases before the IPAB and its perennial non-functioning hold the view that the doctrine of necessity has to be invoked in this case. The Court observed that legislative intent is of the continuity of IPAB and not its cessation because of a vacancy in its technical membership. It clarified that even if the post of the Technical Member is lying vacant, the IPAB can proceed to hear the urgent matters and the orders passed would not suffer invalidity on the ground of lack of Coram.

Applying the doctrine of necessity and following the principles laid down in Election Commission of India Kwality Restaurant W.P.(C) 5571/2019 Page 31 of 32 Talluri Srinivas and Bharat Bijlee Limited, the Court held that the Chairman of the IPAB and the Technical Member (Plant Varieties Protection) are competent enough to hear the urgent matters relating to the Patents, Trade Marks and Copyright till the vacancies of other Technical Members are filled up and the orders passed would not suffer invalidity on the ground of lack of Coram.

Conclusion:

  1. The Chairman of the IPAB and the Technical Member (Plant Varieties Protection) have been directed to take up the stay application of the petitioner (for the present case) for hearing in terms of this order and endeavor to decide the same within a period of six weeks.
  2. The Chairman of the IPAB and the Technical Member (Plant Varieties Protection) are at liberty to take up other urgent matters relating to the Patents, Trade Marks and Copyright.
  3. The petitioner’s submission mentioned and the suggestions of the learned amicus curiae shall be considered on the next date of hearing.

The next date of hearing is slated for August 20, 2019 and more action is expected since this matter is too important to be settled so easily for once and all.

Swarup Kumar
Chair - Group 7: IP Enforcement and Alternate Dispute Resolution
Study & Work Commission
 
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Indian Intellectual Property Office Publishes Draft Patent (Amendment) Rules

The Indian Patent Office (IPO) published Draft Patent (Amendment) Rules, 2019 on 1 June 2019 and asked for submission of comments and/or suggestions by stakeholders within one month of publication of such draft Rules.

FICPI-India, keeping its tradition of engagement with the IPO, studied the amended draft Rules and in consultation with its membership finalised and submitted detailed comments and suggestions with respect to the amendments proposed in the draft Rules on June 29, 2019. FICPI-India made the following submissions to the IPO on amended draft Rules:

FICPI-India’s submission/suggestions of draft Patents (Amendment) Rules, 2019

FICPI India appreciates publication of draft Patents (Amendment) Rules, 2019. There are two major amendments proposed in the Patent Rules, i.e. .with respect to Rule 21 and Rule 131 along with amendments to the form and format of Form 27.

FICPI-India’s suggestions and/or comments with respect to the amendments are presented as under:

English Translation of Priority Documents:

  1.  The draft Rules 21(2) states :

“(2) Where priority document referred to in sub-rule (1) is required to be filed under Rule 51bis.1 (e) of Regulations under the Treaty, and if it is not in the English language, an English translation thereof duly verified by the applicant or the person duly authorized by him shall be filed within three months from the date of inviting to file it by the Appropriate Office.

We are of the opinion, that the above draft rule is not clear and open to interpretation by the Controllers, who in our experience, are rigid about the formal requirements.

The requirement of submitting priority document in national phase only arises if the applicant has not submitted it in the international phase under Rule 17(1)(a) or (b) . In the event of non-English priority document, the translation should be filed in the national stage in India within 3 months of request by the Controller.

However, the proviso clause of 51bis (1)(e) , which says that ‘…..provided that such a translation may only be required (i) where the validity of priority claim is relevant to the determination of whether the invention concerned is patentable; (i.e. if the Indian Controller relies on a publication between the priority date and the effective filing date.) is often disregarded.

Further, the provisions of Rule 23 which states that in the event of conflict between Indian rules and those of PCT , the PCT Regulations etc will prevail is also disregarded.

Moreover, Rule 51bis 1(e) is not about priority document but about its English translation.

Hence , the draft Rule may be amended somewhat as :

“(2) Where priority document referred to in sub-rule (1) is required to be filed under Rule  17.1(c) [ 51bis 1(e)]  of the Regulations under the Treaty, and if it is not in the English language, an English translation thereof duly verified by the applicant or the person duly authorized by him shall be filed , within three months from the date of inviting to file it by the Appropriate Office, provided that said translation is only required according to the provisions of rule 51bis(1)(e) of the Regulations.”

Our members are however not sure, if the draft rules are framed to make such English translation mandatory or to comply with the requirements under 51bis 1(e). In our opinion, this requirement is unwarranted as the Indian Controller’s seldom goes beyond the prosecution history of corresponding applications and almost never ascertain the priority dates of individual claims for which they would need such a translation.

Working of Patents:

  1. FICPI-India welcomes the changes proposed to Rule 131 and is appreciative of the relief provided towards non-filing of statement of working for 1st year of Patent.
  1. FICPI-India also welcomes that the proposed draft Form 27 is simpler and some of the previous undesirable requirements have now been excluded from therein. It is, however, respectfully submitted that certain specific issues still remain and they need to be addressed.
  1. Form 27 should only be restricted to a declaration of working/non-working. Practically, to achieve the intended purpose of Form 27, it is sufficient for the statement of working to be restricted to a declaration as to whether the patent has been worked or not worked. This may be supplemented by reasons for not working.
  1. In addition to the categories “Worked” and “Not worked” at point 3 of Form 27, as suggested in our previous submission dated March 27, 2019, a third category, “May have worked” should as well be included. This will address the situations when even though a patent may have been worked by one or more of the licensees, the Patentee are not be aware of specific details.
  1. Additional details such as quantum and value of the patented product (in rupees), should, not be included and if at all, included be made optional, since it compromises confidential-business sensitive information of patentees. Form 27, unintentionally, gives trade competitors easy access to the confidential information, which they might not have had access to otherwise, even after conducting a thorough market intelligence. This requirement therefore, should only be made compulsory in a compulsory licensing proceeding and should not be a “required” information for every patentee.
  1. It will be appreciated that there are certain technology areas where it may not be possible to comprehend the value so accrued as required to be disclosed by amended Form 27.  For instance, for patents relating to software and telecommunication, often multiple patents involved and they imbibe references to cross licensed patents. In these scenarios, it is not feasible to disclose value accrued by all the patents in the patents pool of a patentee. Not only this, one product/one process does not always correspond to a single patent since in many instances, a product or a method is covered by portfolio of patents maintained by different patentees. In these cases as well, the actual or true value of the worked invention cannot be fathomed and stated in Form 27.
  1. In the proposed Form 27, at point 6, the reference to ‘authorized registered patent agent’ should as well be included to make such aspect consistent with Rule 131(1). Signing authority for Form 27 cannot only be the Patentee and/or Licensee and registered patent argents cannot be excluded from this capacity when it is not the case for all other relevant/pertinent Forms under the Act.
  1. Obligation to file Form 27 should rest with either the patentee or the licensee and not on both of them. No point in duplicating the efforts for submission of the same or substantively similar information especially when a patent has been worked via only a single licensee.

FICPI-India, in its letter to the IPO, also requested the Controller General to include (just like in the past) its representative(s) in the further discussion of the topic during future stakeholders meeting on the draft Rules.

Swarup Kumar
Chair - Group 7: IP Enforcement and Alternate Dispute Resolution
Study & Work Commission
 
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South Africa – Anticipated Increase in Official Fees for Patents and Designs

Earlier in 2019, the Companies and Intellectual Property Commission (CIPC) indicated that official fees for South African patents and designs were to be increased.  In addition, a distinction was in future to be drawn between small and large entities, insofar as the filing and renewal of patents and designs are concerned.
 
It was initially expected that the fee increase would be effective as from 1 July 2019, but the changes were put on hold.  It has now been advised that the date of implementation is likely to be 1 October 2019, although that could also change.
 
It is understood that the official fees for patent & design applications, and for corresponding renewals, will increase significantly insofar as large entities are concerned.  In addition, a general 5% official fee increase will be applied to all other official fees, and provision is to be made for a regular annual increase of 5% going forward.
 
The anticipated revised official fees for applications and renewals are set out below.  These are subject to confirmation once the changes have been officially promulgated.
 

Action Current official fee (ZAR) Proposed official fee (ZAR)
Patent application (small entity) 590.00 590.00
Patent application (large entity) 590.00 1100.00
Patent renewal (small entity) Variable 85.00 – 206.00 140.00
Patent renewal (large entity) Variable 85.00 – 206.00 1400.00
Design application (small entity) 240.00 240.00
Design application (large entity) 240.00 540.00
Design renewal (small entity) Variable 77.00 – 149.00 100.00
Design renewal (large entity) Variable 77.00 – 149.00 1000.00
 
The proposed definition of a small entity is complex and is based on the definition of a “small enterprise” as contained in the National Small Enterprise Act, No. 102 of 1996, as amended (*see relevant extract below).  In many instances it may be difficult to ascertain readily whether an applicant or patentee qualifies as a small entity.  It is believed (at this stage at any rate) that it may be preferable to pay official fees at the large entity rate unless one is absolutely certain that the patentee qualifies for the lower rate.
 
Furthermore, it is understood that applicants claiming small entity status will be required to lodge a prescribed declaration attesting to the fact that they qualify for the reduced rates, at the time an application is filed (or possibly within a few months of filing).  Similarly, owners renewing and wishing to take advantage of the small entity reductions will likewise be obliged to lodge a declaration attesting to the fact that they comply with the requirement for small entity status, at the time of making a renewal payment.  If no such declaration is lodged, large entity rates will apply.
 
Future developments and confirmation of the implementation date will be reported in due course.
 
*Extract from the South African National Small Enterprise Act 102 of 1996:
“Small enterprise” means a separate and distinct business entity, together with its branches or subsidiaries, if any, including co-operative enterprises, managed by one owner or more predominantly carried on in any sector or subsector of the economy mentioned in column 1 of the Schedule and classified as a micro-, a small or a medium enterprise by satisfying the criteria mentioned in columns 3 and 4 of the Schedule.
The Schedule referenced above is contained in the South African Small Business Amendment Act 26 of 2003.  The table below excludes the rules for “small”, “very small” and “micro” enterprises, as the cut-off for qualification for reduced official fees is a “medium” enterprise.
 
Column 1 Column 2 Column 3 Column 4 Column 5
Sector or subsector in accordance with the Standard Industrial Classification Size of class The total full-time equivalent of paid employees Total turnover Total gross asset value (fixed property excluded)
Agriculture Medium 100 R5m R5m
Mining and Quarrying Medium 200 R39m R23m
Manufacturing Medium 200 R51m R19m
Electricity, Gas and Water Medium 200 R51m R19m
Construction Medium 200 R26m R5m
Retail and Motor Trade and Repair Services Medium 200 R39m R6m
Wholesale Trade, Commercial Agents and Allied Services Medium 200 R64m R10m
Catering, Accommodation and other Trade Medium 200 R13m R3m
Transport, Storage and Communications Medium 200 R26m R6m
Finance and Business Services Medium 200 R26m R5m
Community, Social and Personal Services Medium 200 R13m R6m

 

Mark Kemp
Reporter - Group 5: Biotechnology and Pharmaceuticals
Study & Work Commission
 
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New Rules of Procedure of the EPO Boards of Appeal from 1 January 2020

As reported in the FICPI News of 22 January 2019, a revised version of the Rules of Procedure [https://www.epo.org/law-practice/case-law-appeals/communications/2019/20190704.html] of the Boards of Appeal of the European Patent Office (EPO) will enter into force on 1 January 2020.

The revised rules will apply also to pending appeals (with some exceptions under Article 25, see below) and include a new “convergent approach”, which is aimed to progressively limit the possibility of submitting new arguments or evidence during appeal proceedings, according to the following scheme, based on three levels:

First level – Article 12(2-4): “the primary object of the appeal proceedings” is “to review the decision under appeal in a judicial manner”, so that already at the outset of the appeal proceedings the Boards shall exercise their discretion in admitting “amendments”, i.e. requests, facts, objections, arguments and evidence which were not presented during the proceedings of first instance;

Second level – Article 13(1): “any amendment to a party’s appeal case after it has filed its grounds of appeal or reply” not only may be admitted at the discretion of the Board, as in the first level, but shall also be “subject to the party’s justification for its amendment”;

Third level – Article 13(2): “any amendment to a party’s appeal case made after the expiry of a period specified by the Board in a communication under Rule 100, paragraph 2, of the European Patent Convention (EPC) [i.e. an invitation to file observations] or, where such a communication is not issued, after notification of a summons to oral proceedings shall not, in principle, be taken into account unless there are exceptional circumstances, which have been justified with cogent reasons by the party concerned.”

The revised rules also include the following important changes:

Article 1(2): the President of the Boards of Appeal shall, before the beginning of each working year, publish a list of the cases in which each Board “is likely to hold oral proceedings, issue a communication under Rule 100, paragraph 2, EPC, or issue a decision in written proceedings in that year”;

Article 5(3): each rapporteur “shall, subject to the direction of the Chair of the Board, assess whether the appeal should be given priority over, or should be treated together with, other appeals assigned to the rapporteur”;

Article 10(3-5): the Boards may accelerate an appeal either of their own motion or if a party provides reasons and “documentary evidence” justifying the acceleration or if a court, including the UPC, or other competent authority in a Contracting State, requests acceleration;

Article 11: the Boards shall not remit a case to the department of first instance for further prosecution “unless special reasons present themselves for doing so”, which special reasons include “fundamental deficiencies” in the proceedings of first instance;

Article 12(7): the four-month period for replying to the grounds of appeal may exceptionally be extended up to a maximum of six months “at the Board’s discretion upon a written and reasoned request, presented before the expiry of such period”;

Article 15(1): the Boards shall endeavour to issue the summons to oral proceedings no earlier than two months after receipt of the reply(ies) to the grounds of appeal, shall issue a “communication drawing attention to matters that seem to be of particular significance”, in most cases with a “preliminary opinion”, and shall endeavour to issue this communication and to give notice of the summons at least four months in advance of the date of the oral proceedings;

Article 15(2): the Boards may change the date for oral proceedings only for “serious reasons”, which should relate only to the representative, if a party is represented;

Article 15(7): the Boards may issue the reasons for a decision “in abridged form”, provided that the parties have given “explicit consent” and that a third party or a court does not have a legitimate interest in non-abridged reasons;

Article 15(9): the Boards shall endeavour to issue their decisions within three months from the date of the oral proceedings;

Article 25(2): the first level of the “convergent approach” will not apply to the grounds of appeal filed before 1 January 2020 and any reply thereto filed in due time;

Article 25(3): the third level of the “convergent approach” will not apply if the summons to oral proceedings or a communication inviting a party to file observation has been notified before 1 January 2020.

In view of the above, it is clear that “amending” a case will be more difficult already at the beginning of appeal proceedings, i.e. when filing the grounds of appeal or the reply thereto, and almost impossible at a later stage. Therefore, any possible document, request or argument should be filed during the first instance proceedings or before 1 January 2020 if appeal proceedings have just started.

Moreover, care should be taken if a document, request or argument is considered for the first time by a Board when a case has not been remitted to the department of first instance, since appeal proceedings are the last instance for discussing the validity of a European patent if this patent is then revoked by the Board.

Antonio Pizzoli
Chair - Group 4: European Patents
Study & Work Commission

 
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FICPI CET5 Addresses Arising Issues in the Biotechnology and Pharmaceutical Fields

CET5 (or “Group 5”), the Biotechnology and Pharmaceutical working group of FICPI, has active members in Austria, Australia, Brazil, China, Denmark, Germany, India, Ireland, Italy, Japan, Korea, Poland, Portugal, South Africa, Spain, Turkey, the United Kingdom and the United States.  The group met in person in June of 2018 at the FICPI World Congress, and will meet again at the FICPI Forum in Vienna, Austria in October of 2019.  In the interim, CET5 strives to have monthly telephone conferences to keep its members up to date on ongoing projects and developing issues in intellectual property as it pertains to biotechnology and pharmaceuticals.

Chairs of all the CET groups met in Turin, Italy in April of 2019 in connection with the FICPI Executive Committee (“ExCo”) meeting.  Francesco Paolo Vatti (IT) presented a resolution, which was overwhelmingly passed by FICPI national delegates, on 3D printing of biological tissues and organs, a technology that provides a solution to the limited number of available tissues and organs for transplantation.  The resolution noted that such 3D printed tissues and organs are creations of human innovation, do not exist in nature, and therefore should be eligible for patent protection.  Mr. Vatti had previously drafted a FICPI position paper on the topic.

Just prior to the Turin ExCo, FICPI, along with AIPPI and AIPLA, held a colloquium on Artificial Intelligence, which focused on four issues: (1) patent eligibility, (2) inventiveness, (3) sufficiency of disclosure, and (4) inventorship (in particular with regard to subject-matter that is wholly or in part created by a computer).  A summary of the transcripts from the Colloquium has been generated, and CET5 member, Danny Huntington (US), who was also instrumental in initiating and organizing the Colloquium (along with other FICPI members, including CET5 members MaryAnne Armstrong [US] and Roberto Pistolesi (IT)), will be preparing a news item and an information paper as the issues relate specifically to biotechnology and pharmaceuticals.

Joao Jorge (PT) and Susanne Hantos (AU) are in the process of analyzing the prior art effect of virtual compounds for an information paper, which may ultimately lead to a resolution.  Likewise, Rana Gosain (BR) and Vidisha Garg (IN) are preparing a questionnaire regarding the patentability of polymorphs on a country-by-country basis.  Biodiversity and associated national laws are also being addressed within CET5 by Deepa Tiku (IN) and Rana Gosain (BR), to address procedures and regulations in those countries regarding the disclosure of biological resources and their origins.  Danny Huntington (US) is also monitoring the progress of the Intergovernmental Committee (IGC) on traditional cultural expressions (TCE) and genetic resources (GRs).  Rowan Joseph (ZA) has prepared a summary and continues to monitor the Pat-INFORMED database, which is a database developed by a number of global research-based biopharmaceutical companies, supported by WIPO and International Federation of Pharmaceutical Manufacturers and Associations (IFPMA), in which patents are listed against active agents.  Rafal Witek (PL) is preparing a news item regarding the manufacturing waiver in connection with Supplementary Protection Certificates.

A questionnaire is being developed with regard to policies and procedures for examining claims to antibodies (Archana Shanker [IN], Sharon Crane [US] and Chris Mercer [UK]), with a particular focus on the breadth of claims to such subject matter as it varies among countries.  In addition, a questionnaire is being drafted by Sharon Crane (US), MaryAnne Armstrong (US) and Abhai Pandey (IN) regarding subject matter eligibility. 

The issue of subject matter eligibility has been a highly controversial topic, particularly in the US, in light of Supreme Court decisions in the Mayo[1], Myriad[2] and Alice cases[3], and Sharon Crane (US) has written several FICPI news items on the topic.  Dr. Crane recently attended day one of hearings of the Senate Judiciary Subcommittee on Intellectual Property, and worked with

FICPI Member of Honor, former Chief Judge of the Court of Appeals for the Federal Circuit Paul Michel, as well as FICPI President Julian Crump (UK), CET6 Chair Brett Slaney and CET Vice Presidents Robert Watson (UK), and Michael Caine (AU), to draft a letter to U.S. Congress with FICPI’s recommendations regarding the Draft Bill Text to Reform Section 101 of the Patent Act.

CET5 continues to monitor and present to the CET and FICPI national delegates current issues regarding intellectual property protection of inventions in the biotechnology and pharmaceutical fields.

[1] Mayo Collaborative Services v. Prometheus Laboratories, Inc., 566 U.S. 66, 132 S. Ct. 1289, 101 USPQ2d 1962 (2012).

[2] Association for Molecular Pathology v. Myriad Genetics, Inc., 569 U.S. 576, 133 S. Ct. 2107, 106 USPQ2d 1972 (2013).

[3] Alice Corporation Pty. Ltd. v. CLS Bank International, 573 U.S. 208, 134 S. Ct. 2347, 110 U.S.P.Q.2d 1976 (2014).


Sharon E. Crane, Ph.D
Chair - Group 5: Biotechnology and Pharmaceuticals
Study & Work Commission

 
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