Request for Comments Regarding the Impact of the Proliferation of Artificial Intelligence on Prior Art, the Knowledge of a Person Having Ordinary Skill in the Art, and Determinations of Patentability Made in View of the Foregoing, 34217-34220 [2024-08969]
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Patent and Trademark Office
Request for Comments Regarding the
Impact of the Proliferation of Artificial
Intelligence on Prior Art, the
Knowledge of a Person Having
Ordinary Skill in the Art, and
Determinations of Patentability Made
in View of the Foregoing
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The United States Patent and
Trademark Office (USPTO or Office)
seeks public comments regarding the
impact of the proliferation of artificial
intelligence (AI) on prior art, the
knowledge of a person having ordinary
skill in the art (PHOSITA), and
determinations of patentability made in
view of the foregoing. The increasing
power and deployment of AI has the
potential to provide tremendous societal
and economic benefits and foster a new
wave of innovation and creativity while
also posing novel challenges and
opportunities for intellectual property
(IP) policy. Through the AI and
Emerging Technologies Partnership (AI/
ET Partnership), the USPTO has been
actively engaging with the innovation
community and AI experts on IP policy
in view of AI. To build on these efforts,
the USPTO is requesting written public
comments on how the proliferation of
AI could affect certain evaluations made
by the Office, including what qualifies
as prior art, the assessment of the level
of skill of a PHOSITA, and
determinations of patentability made in
view of these evaluations. The USPTO
expects that the responses received will
help the Office evaluate the need for
further guidance on these matters, aid in
the development of any such guidance,
and help inform the USPTO’s work in
the courts and in providing technical
advice to Congress.
DATES: Written comments must be
received on or before July 29, 2024, to
ensure consideration.
ADDRESSES: Comments must be
submitted through the Federal
eRulemaking Portal at
www.regulations.gov. To submit
comments via the portal, enter docket
number PTO–P–2023–0044 on the
homepage and click ‘‘Search.’’ The site
will provide a search results page listing
all documents associated with this
docket. Find a reference to this
document and select the ‘‘Comment’’
SUMMARY:
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icon, complete the required fields, and
enter or attach your comments.
Attachments to electronic comments
will be accepted in ADOBE® portable
document format (PDF) or Microsoft
Word® format. Because comments will
be made available for public inspection,
information that the submitter does not
desire to make public, such as an
address or phone number, should not be
included in the comments.
Visit the Federal eRulemaking Portal
for additional instructions on providing
comments via the portal. If electronic
submission of comments is not feasible
due to a lack of access to a computer
and/or the internet, please contact the
USPTO using the contact information
below for special instructions.
FOR FURTHER INFORMATION CONTACT:
Steven J. Fulk, Legal Advisor, at 571–
270–0072; Nalini Mummalaneni, Senior
Legal Advisor, at 571–270–1647; or
Matthew Sked, Senior Legal Advisor, at
571–272–7627, all with the Office of
Patent Legal Administration, Office of
the Deputy Commissioner for Patents.
SUPPLEMENTARY INFORMATION:
I. Background
The USPTO has held several
stakeholder interaction sessions and has
issued requests for comments (RFCs) to
seek public feedback regarding AI’s
impact on patent policy issues.1 In
August 2019, the USPTO issued an RFC
on patenting AI inventions.2 Among the
various policy questions raised in this
previous RFC, the USPTO requested
comments on AI’s impact on a
PHOSITA and prior art considerations
unique to AI inventions.3 In October
2020, the USPTO published a report
titled ‘‘Public Views on Artificial
Intelligence and Intellectual Property
Policy,’’ which provided a
comprehensive look at the stakeholder
feedback received in response to the
questions posed in the August 2019
RFC.4 That report explained that
stakeholders had varying views on how
AI would impact obviousness
determinations and how to assess a
PHOSITA’s level of skill.5 Some
commenters stated that AI machines are
not ‘‘persons,’’ and therefore, AI would
1 See USPTO Artificial Intelligence web page at
www.uspto.gov/initiatives/artificial-intelligence.
2 Request for Comments on Patenting Artificial
Intelligence Inventions, 84 FR 44889 (August 27,
2019). Question 1 of this RFC noted, ‘‘Inventions
that utilize AI, as well as inventions that are
developed by AI, have commonly been referred to
as ‘AI inventions.’ ’’
3 Id.
4 The full report is available at www.uspto.gov/
sites/default/files/documents/USPTO_AI-Report_
2020-10-07.pdf (October 2020 AI Report).
5 October 2020 AI Report at 11–13.
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not affect the PHOSITA assessment.6
Additional commenters believed the
present framework for assessing a
PHOSITA’s level of skill is sufficient to
determine the impact of AI in a
particular field.7 Many commenters
agreed that the increasing use of AI
would affect how the USPTO and the
courts assess the legal hypothetical
standard of a PHOSITA.8 Others
indicated ‘‘the level of skill in any art
has traditionally grown over time based
on the introduction of new technologies
and that ‘once conventional AI systems
become widely available . . . such
accessibility would be expected to
enhance the abilities of a
[PHOSITA].’ ’’ 9 However, some
commenters noted that ‘‘such wide
prevalence of AI systems has not yet
permeated all fields and counseled
against declaring that all fields of
innovation are now subject to the
application of ‘conventional AI.’ ’’ 10
Additionally, while most commenters
believed there were no prior art
considerations unique to AI, some
commenters indicated there may be
some unique considerations, such as the
difficulty in finding prior art related to
the AI technology itself (e.g., finding
source code for AI technology) and the
proliferation of AI-generated prior art.11
Overall, commenters confirmed that
more engagement with the USPTO was
needed regarding how AI impacts prior
art and the level of skill of a PHOSITA.
In June 2022, the USPTO launched
the AI/ET Partnership.12 At the June 29,
2022, inaugural AI/ET Partnership
meeting,13 panelists commented that the
level of skill of a PHOSITA for
obviousness determinations would be
higher in view of the availability of AI.14
One panelist argued that it may be
appropriate to raise the bar for the level
of skill of a PHOSITA particularly
where the use of AI is common practice.
That panelist also noted that AI might
be able to make use of prior art from
fields that humans may not have been
at 13.
at 12.
8 Id. at iii.
9 Id.
10 Id. at 13.
11 Id. at 13–14.
12 Events for the Artificial Intelligence and
Emerging Technologies Partnership, 87 FR 34669
(June 7, 2022).
13 A video of the meeting is available at
www.uspto.gov/about-us/events/aiet-partnershipseries-1-kickoff-uspto-aiet-activities-and-patentpolicy.
14 A higher level of ordinary skill in the art would
more likely support the conclusion that a PHOSITA
would recognize that the differences between a
claimed invention and the prior art are such that
the claimed invention would have been obvious.
See, e.g., In re GPAC Inc., 57 F.3d 1573 (Fed. Cir.
1995) (GPAC); see also Section III of this notice.
expected to find or use, and that the
universe of prior art would expand as AI
advances. Another panelist commented
that obviousness is always determined
in view of prior art references and that
the extent to which AI developments
should affect the obviousness standard
was unclear. After this June 2022
inaugural event, the Office held several
additional AI/ET Partnership events in
2022 and 2023.15
In February 2023, the USPTO issued
an RFC on AI and inventorship.16 This
request focused on questions of
inventorship, but it also asked what
other areas of focus the USPTO should
prioritize in future engagements. Many
commenters indicated that the USPTO
should investigate how AI impacts
obviousness determinations and the
PHOSITA assessment.17 For example,
some commenters stated that an
invention developed with the use of AI
should not render that invention
obvious or more likely to be obvious.18
Conversely, other commenters indicated
that AI contributions to an invention
should be per se obvious or that the AI
contribution should have a rebuttable
presumption of obviousness.19
Commenters also indicated that AI has
the potential to generate a vast amount
of prior art, which may have an impact
on the Office’s anticipation and
obviousness determinations.20
The increasing power and
deployment of AI has the potential to
provide tremendous societal and
economic benefits and foster a new
wave of innovation and creativity while
also posing novel challenges and
opportunities for IP policy. Based on the
feedback that the USPTO has received
from our stakeholders on the
importance of AI’s impact on prior art,
on the knowledge of a PHOSITA, and on
other patentability considerations, the
Office plans to more deeply engage with
stakeholders and is requesting further
comments in these areas. This RFC
builds on the USPTO’s recent AI-related
efforts associated with Executive Order
6 Id.
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7 Id.
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15 See AI and Emerging Technology Partnership
engagement and events web page at www.uspto.gov/
initiatives/artificial-intelligence/ai-and-emergingtechnology-partnership-engagement-and-events.
16 Request for Comments Regarding Artificial
Intelligence and Inventorship, 88 FR 9492 (February
14, 2023) (February 2023 AI RFC).
17 Comments in response to the February 2023 AI
RFC are available at www.regulations.gov/docket/
PTO-P-2022-0045.
18 See, e.g., Comment PTO–P2022–0045–0052
(AUTM).
19 See, e.g., Comment PTO–P2022–0045–0057
(Alliance for Automotive Innovation), and
Comment PTO–P2022–0045–0063 (The Computer &
Communications Industry Association and The
Public Innovation Project).
20 See, e.g., Comment PTO–P2022–0045–0013
(James Gatto).
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14110,21 including the ‘‘Inventorship
Guidance for AI-Assisted Inventions’’ 22
published on February 13, 2024.
Section II of this notice provides an
overview of prior art considerations and
discusses some concerns relevant to AIgenerated prior art. Section III discusses
the current PHOSITA assessment as it is
applied by the USPTO and the courts.
Sections II and III are intended only to
provide context for the questions
presented in this notice. This RFC is not
a guidance document and does not
announce any new Office practice or
procedure. Section IV presents
questions to the public on the impact of
AI on prior art and the PHOSITA
assessment.
II. Considerations for the Impact of AI
on Prior Art
‘‘A claimed invention may be rejected
under 35 U.S.C. 102 when the invention
is anticipated (or is ‘not novel’) over a
disclosure that is available as prior art.
To reject a claim as anticipated by a
[prior art] reference, the disclosure must
teach every element required by the
claim under its broadest reasonable
interpretation.’’ 23 Under 35 U.S.C.
102(a)(1), a person is not entitled to a
patent if the claimed invention was
disclosed—including being patented;
described in a printed publication; or in
public use, on sale, or otherwise
available to the public—before the
effective filing date of the claimed
invention (i.e., the disclosure is a ‘‘prior
art disclosure’’). Under 35 U.S.C.
102(a)(2), a person is not entitled to a
patent if ‘‘the claimed invention was
described in a patent issued under [35
U.S.C. 151], or in an application for
patent published or deemed published
under [35 U.S.C. 122(b)], in which the
patent or application, as the case may
be, names another inventor and was
effectively filed before the effective
filing date of the claimed invention.’’ A
disclosure that is a prior art reference
under 35 U.S.C. 102 may also serve as
a basis for obviousness under 35 U.S.C.
103.24
To qualify as a ‘‘printed publication’’
under 35 U.S.C. 102(a)(1), a prior art
reference must have been publicly
accessible, i.e., ‘‘available to the extent
that persons interested and ordinarily
skilled in the subject matter or art,
exercising reasonable diligence, can
21 Executive Order on the Safe, Secure, and
Trustworthy Development and Use of Artificial
Intelligence, Executive Order 14110, 88 FR 75191
(November 1, 2023).
22 Inventorship Guidance for AI-Assisted
Inventions, 89 FR 10043 (February 13, 2024).
23 Manual of Patent Examining Procedure (MPEP)
2131.
24 MPEP 2141.01, subsection I; MPEP 2141.01(a).
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locate [the reference].’’ 25 AI may be
used to create vast numbers of
disclosures that may have been
generated without any human
contribution, supervision, or review.
Because a PHOSITA is ‘‘a hypothetical
person who is presumed to have known
the relevant art at the relevant time,’’ 26
the proliferation of AI-generated
disclosures may question the soundness
of presuming that a PHOSITA knew of
relevant AI-generated art when the vast
amount of AI-generated disclosures was
never reviewed by a human. Further, as
suggested by stakeholders, there is a
question whether AI-generated
disclosures, especially those with no
human input, review, or validation,
should qualify as prior art disclosures
and potentially preclude human-created
inventions from being patented.
Additionally, ‘‘[w]hen the [prior art]
reference relied on expressly anticipates
or makes obvious all of the elements of
the claimed invention, the reference is
presumed to be operable,’’ regardless of
the type of prior art (e.g., patent, printed
publication, or other prior art
disclosure), and the burden is on the
applicant to rebut the presumption of
operability.27 The presumption is that a
public disclosure provides a description
that enables the public to make and use
the disclosure. The presumption does
not (at least currently) distinguish
between who or what made the
disclosure, which prompts the question
whether AI-generated disclosures (that
have not been prepared and reviewed by
a human) should be afforded the same
rebuttable presumption that they are
operable and enabled. In view of the
above issues, the proliferation of AIgenerated prior art raises questions on
which the Office seeks input from
stakeholders.
III. Considerations for the Impact of AI
on the Knowledge of a PHOSITA
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‘‘A patent for a claimed invention
may not be obtained . . . if the
differences between the claimed
invention and the prior art are such that
the claimed invention as a whole would
have been obvious before the effective
filing date of the claimed invention to
a person having ordinary skill in the art
to which the claimed invention
25 MPEP 2128, subsection I (quoting In re Wyer,
655 F.2d 221, 210 USPQ 790 (C.C.P.A. 1981)
(quoting I.C.E. Corp. v. Armco Steel Corp., 250 F.
Supp. 738, 743, 148 USPQ 537, 540 (SDNY 1966))).
26 MPEP 2141.03, subsection I.
27 MPEP 2121, subsections I and II. Note,
however, ‘‘[e]ven if a reference discloses an
inoperative device, it is prior art for all that it
teaches’’ and ‘‘may qualify as prior art for the
purpose of determining obviousness under 35
U.S.C. 103.’’ MPEP 2121.01, subsection II.
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pertains.’’ 28 Thus, obviousness is to be
determined with regard to a
PHOSITA.29 As reiterated by the
Supreme Court in KSR International Co.
v. Teleflex Inc.30 (KSR), obviousness is
a question of law based on underlying
factual inquiries established in Graham
v. John Deere Co. (Graham).31 The
Graham factual inquiries are: (1)
determining the scope and content of
the prior art, (2) ascertaining the
differences between the claimed
invention and the prior art, (3) resolving
the level of ordinary skill in the art, and
(4) evaluating any objective evidence of
nonobviousness.32 Once these factual
findings are made, a determination of
obviousness should focus on ‘‘what a
person of ordinary skill in the pertinent
art would have known at the relevant
time, and on what such a person would
have reasonably expected to have been
able to do in view of that knowledge.’’ 33
Likewise, a patent ‘‘specification shall
contain a written description of the
invention, and of the manner and
process of making and using it, in such
full, clear, concise, and exact terms as
to enable any person skilled in the art
to which it pertains . . . to make and
use the same.’’ 34 The courts have
analyzed written description and
enablement issues from the vantage
point of a PHOSITA.35 However, the
role of a PHOSITA goes beyond these
statutory considerations for obviousness
under 35 U.S.C. 103 and the
requirements under 35 U.S.C. 112. For
example, claim terms are construed in
the manner in which a PHOSITA would
understand them.36 Additionally,
claims can be anticipated by prior art
inherently if ‘‘the missing descriptive
matter is necessarily present in the thing
described in the reference, and that it
28 35
U.S.C. 103 (emphasis added).
2141.
30 550 U.S. 398, 406 (2007).
31 383 U.S. 1, 17–18 (1966). The Office recently
published ‘‘Updated Guidance for Making a Proper
Determination of Obviousness’’ (89 FR 14449
(February 27, 2024)), which provides a review of
the flexible approach to determining obviousness
required by KSR.
32 MPEP 2141, subsection II.
33 Id.
34 35 U.S.C. 112(a) (emphasis added).
35 MPEP 2163.02 (‘‘An objective standard for
determining compliance with the written
description requirement is, ‘does the description
clearly allow persons of ordinary skill in the art to
recognize that he or she invented what is claimed.’
In re Gosteli, 872 F.2d 1008, 1012, 10 USPQ2d
1614, 1618 (Fed. Cir. 1989)’’); MPEP 2164.02
(‘‘Allergan, Inc. v. Sandoz Inc., 796 F.3d 1293,
1310, 115 USPQ2d 2012, 2023 (Fed. Cir. 2015)
(‘Only a sufficient description enabling a person of
ordinary skill in the art to carry out an invention
is needed.’)’’).
36 MPEP 2111.
29 MPEP
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would be so recognized by persons of
ordinary skill.’’ 37
The Court of Appeals for the Federal
Circuit has identified several factors to
consider when determining a
PHOSITA’s level of skill, including the
type of problems encountered in the art,
prior art solutions to those problems,
the rapidity with which innovations are
made, the sophistication of the
technology, and the education level of
active workers in the field.38 Each case
may vary, not every one of the
aforementioned factors may be present,
and one or more factors may
predominate the analysis.39
Accordingly, it is often critical in a
patentability inquiry to assess the
PHOSITA’s level of skill in the relevant
art,40 including for claim construction,
anticipation, obviousness, written
description, and enablement. In view of
the above issues, the proliferation of AI
as a tool for a PHOSITA raises questions
on which the Office seeks input.
IV. Questions for Public Comment
The questions enumerated below
should not be taken as an indication
that the USPTO has taken a position on
or is predisposed to any particular
views. The USPTO welcomes comments
from the public on any issues that are
relevant to this topic, and is particularly
interested in answers to the following
questions:
A. The Impact of AI on Prior Art
1. In what manner, if any, does 35
U.S.C. 102 presume or require that a
prior art disclosure be authored and/or
published by humans? In what manner,
if any, does non-human authorship of a
disclosure affect its availability as prior
art under 35 U.S.C. 102?
2. What types of AI-generated
disclosures, if any, would be pertinent
to patentability determinations made by
the USPTO? How are such disclosures
currently being made available to the
public? In what other ways, if any,
should such disclosures be made
available to the public?
3. If a party submits to the Office a
printed publication or other evidence
that the party knows was AI-generated,
should that party notify the USPTO of
this fact, and if so, how? What duty, if
any, should the party have to determine
whether a disclosure was AI-generated?
4. Should an AI-generated disclosure
be treated differently than a non-AI37 MPEP 2131.01, subsection III (citing
Continental Can Co. v. Monsanto Co., 948 F.2d
1264, 1268 (Fed. Cir. 1991)).
38 MPEP 2141.03, subsection I (citing GPAC, 57
F.3d at 1579).
39 Id.
40 MPEP 2141.03.
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generated disclosure for prior art
purposes? For example:
a. Should the treatment of an AIgenerated disclosure as prior art depend
on the extent of human contribution to
the AI-generated disclosure?
b. How should the fact that an AIgenerated disclosure could include
incorrect information (e.g.,
hallucinations) affect its consideration
as a prior art disclosure?
c. How does the fact that a disclosure
is AI-generated impact other prior art
considerations, such as operability,
enablement, and public accessibility?
5. At what point, if ever, could the
volume of AI-generated prior art be
sufficient to create an undue barrier to
the patentability of inventions? At what
point, if ever, could the volume of AIgenerated prior art be sufficient to
detract from the public accessibility of
prior art (i.e., if a PHOSITA exercising
reasonable diligence may not be able to
locate relevant disclosures)?
B. The Impact of AI on a PHOSITA
6. Does the term ‘‘person’’ in the
PHOSITA assessment presume or
require that the ‘‘person’’ is a natural
person, i.e., a human? How, if at all,
does the availability of AI as a tool affect
the level of skill of a PHOSITA as AI
becomes more prevalent? For example,
how does the availability of AI affect the
analysis of the PHOSITA factors, such
as the rapidity with which innovations
are made and the sophistication of the
technology?
7. How, if at all, should the USPTO
determine which AI tools are in
common use and whether these tools
are presumed to be known and used by
a PHOSITA in a particular art?
8. How, if at all, does the availability
to a PHOSITA of AI as a tool impact:
a. Whether something is well-known
or common knowledge in the art?
b. How a PHOSITA would understand
the meaning of claim terms?
9. In view of the availability to a
PHOSITA of AI as a tool, how, if at all,
is an obviousness determination
affected, including when:
a. Determining whether art is
analogous to the claimed invention,
given AI’s ability to search across art
fields? Does the ‘‘analogous’’ art
standard still make sense in view of AI’s
capabilities?
b. Determining whether there is a
rationale to modify the prior art,
including the example rationales
suggested by KSR (MPEP 2143,
subsection I) (e.g., ‘‘obvious to try’’) or
the scientific principle or legal
precedent rationales (MPEP 2144)?
c. Determining whether the
modification yields predictable results
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with a reasonable expectation of success
(e.g., how to evaluate the predictability
of results in view of the stochasticity (or
lack of predictability) of an AI system)?
d. Evaluating objective indicia of
obviousness or nonobviousness (e.g.,
commercial success, long felt but
unsolved needs, failure of others,
simultaneous invention, unexpected
results, copying, etc.)?
10. How, if at all, does the recency of
the information used to train an AI
model or that ingested by an AI model
impact the PHOSITA assessment when
that assessment may focus on an earlier
point in time (e.g., the effective filing
date of the claimed invention for an
application examined under the FirstInventor-to-File provisions of the
America Invents Act)?
11. How, if at all, does the availability
to a PHOSITA of AI as a tool impact the
enablement determination under 35
U.S.C. 112(a)? Specifically, how does it
impact the consideration of the In re
Wands factors (MPEP 2164.01(a)) in
ascertaining whether the
experimentation required to enable the
full scope of the claimed invention is
reasonable or undue?
C. The Implications of AI That Could
Require Updated Examination
Guidance and/or Legislative Change
12. What guidance from the USPTO
on the impact of AI on prior art and on
the knowledge of a PHOSITA, in
connection with patentability
determinations made by the Office,
would be helpful?
13. In addition to the considerations
discussed above, in what other ways, if
any, does the proliferation of AI impact
patentability determinations made by
the Office (e.g., under 35 U.S.C. 101,
102, 103, 112, etc.)?
14. Are there any laws or practices in
other countries that effectively address
any of the questions above? If so, please
identify them and explain how they can
be adapted to fit within the framework
of U.S. patent law.
15. Should title 35 of the U.S. Code
be amended to account for any of the
considerations set forth in this notice,
and if so, what specific amendments do
you propose, and why?
Katherine K. Vidal,
Under Secretary of Commerce for Intellectual
Property and Director of the United States
Patent and Trademark Office.
[FR Doc. 2024–08969 Filed 4–29–24; 8:45 am]
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E:\FR\FM\30APN1.SGM
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Agencies
[Federal Register Volume 89, Number 84 (Tuesday, April 30, 2024)]
[Notices]
[Pages 34217-34220]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2024-08969]
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DEPARTMENT OF COMMERCE
Patent and Trademark Office
[Docket No. PTO-P-2023-0044]
Request for Comments Regarding the Impact of the Proliferation of
Artificial Intelligence on Prior Art, the Knowledge of a Person Having
Ordinary Skill in the Art, and Determinations of Patentability Made in
View of the Foregoing
AGENCY: United States Patent and Trademark Office, Department of
Commerce.
ACTION: Request for comments.
-----------------------------------------------------------------------
SUMMARY: The United States Patent and Trademark Office (USPTO or
Office) seeks public comments regarding the impact of the proliferation
of artificial intelligence (AI) on prior art, the knowledge of a person
having ordinary skill in the art (PHOSITA), and determinations of
patentability made in view of the foregoing. The increasing power and
deployment of AI has the potential to provide tremendous societal and
economic benefits and foster a new wave of innovation and creativity
while also posing novel challenges and opportunities for intellectual
property (IP) policy. Through the AI and Emerging Technologies
Partnership (AI/ET Partnership), the USPTO has been actively engaging
with the innovation community and AI experts on IP policy in view of
AI. To build on these efforts, the USPTO is requesting written public
comments on how the proliferation of AI could affect certain
evaluations made by the Office, including what qualifies as prior art,
the assessment of the level of skill of a PHOSITA, and determinations
of patentability made in view of these evaluations. The USPTO expects
that the responses received will help the Office evaluate the need for
further guidance on these matters, aid in the development of any such
guidance, and help inform the USPTO's work in the courts and in
providing technical advice to Congress.
DATES: Written comments must be received on or before July 29, 2024, to
ensure consideration.
ADDRESSES: Comments must be submitted through the Federal eRulemaking
Portal at www.regulations.gov. To submit comments via the portal, enter
docket number PTO-P-2023-0044 on the homepage and click ``Search.'' The
site will provide a search results page listing all documents
associated with this docket. Find a reference to this document and
select the ``Comment'' icon, complete the required fields, and enter or
attach your comments. Attachments to electronic comments will be
accepted in ADOBE[supreg] portable document format (PDF) or Microsoft
Word[supreg] format. Because comments will be made available for public
inspection, information that the submitter does not desire to make
public, such as an address or phone number, should not be included in
the comments.
Visit the Federal eRulemaking Portal for additional instructions on
providing comments via the portal. If electronic submission of comments
is not feasible due to a lack of access to a computer and/or the
internet, please contact the USPTO using the contact information below
for special instructions.
FOR FURTHER INFORMATION CONTACT: Steven J. Fulk, Legal Advisor, at 571-
270-0072; Nalini Mummalaneni, Senior Legal Advisor, at 571-270-1647; or
Matthew Sked, Senior Legal Advisor, at 571-272-7627, all with the
Office of Patent Legal Administration, Office of the Deputy
Commissioner for Patents.
SUPPLEMENTARY INFORMATION:
I. Background
The USPTO has held several stakeholder interaction sessions and has
issued requests for comments (RFCs) to seek public feedback regarding
AI's impact on patent policy issues.\1\ In August 2019, the USPTO
issued an RFC on patenting AI inventions.\2\ Among the various policy
questions raised in this previous RFC, the USPTO requested comments on
AI's impact on a PHOSITA and prior art considerations unique to AI
inventions.\3\ In October 2020, the USPTO published a report titled
``Public Views on Artificial Intelligence and Intellectual Property
Policy,'' which provided a comprehensive look at the stakeholder
feedback received in response to the questions posed in the August 2019
RFC.\4\ That report explained that stakeholders had varying views on
how AI would impact obviousness determinations and how to assess a
PHOSITA's level of skill.\5\ Some commenters stated that AI machines
are not ``persons,'' and therefore, AI would
[[Page 34218]]
not affect the PHOSITA assessment.\6\ Additional commenters believed
the present framework for assessing a PHOSITA's level of skill is
sufficient to determine the impact of AI in a particular field.\7\ Many
commenters agreed that the increasing use of AI would affect how the
USPTO and the courts assess the legal hypothetical standard of a
PHOSITA.\8\ Others indicated ``the level of skill in any art has
traditionally grown over time based on the introduction of new
technologies and that `once conventional AI systems become widely
available . . . such accessibility would be expected to enhance the
abilities of a [PHOSITA].' '' \9\ However, some commenters noted that
``such wide prevalence of AI systems has not yet permeated all fields
and counseled against declaring that all fields of innovation are now
subject to the application of `conventional AI.' '' \10\ Additionally,
while most commenters believed there were no prior art considerations
unique to AI, some commenters indicated there may be some unique
considerations, such as the difficulty in finding prior art related to
the AI technology itself (e.g., finding source code for AI technology)
and the proliferation of AI-generated prior art.\11\ Overall,
commenters confirmed that more engagement with the USPTO was needed
regarding how AI impacts prior art and the level of skill of a PHOSITA.
---------------------------------------------------------------------------
\1\ See USPTO Artificial Intelligence web page at www.uspto.gov/initiatives/artificial-intelligence.
\2\ Request for Comments on Patenting Artificial Intelligence
Inventions, 84 FR 44889 (August 27, 2019). Question 1 of this RFC
noted, ``Inventions that utilize AI, as well as inventions that are
developed by AI, have commonly been referred to as `AI inventions.'
''
\3\ Id.
\4\ The full report is available at www.uspto.gov/sites/default/files/documents/USPTO_AI-Report_2020-10-07.pdf (October 2020 AI
Report).
\5\ October 2020 AI Report at 11-13.
\6\ Id. at 13.
\7\ Id. at 12.
\8\ Id. at iii.
\9\ Id.
\10\ Id. at 13.
\11\ Id. at 13-14.
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In June 2022, the USPTO launched the AI/ET Partnership.\12\ At the
June 29, 2022, inaugural AI/ET Partnership meeting,\13\ panelists
commented that the level of skill of a PHOSITA for obviousness
determinations would be higher in view of the availability of AI.\14\
One panelist argued that it may be appropriate to raise the bar for the
level of skill of a PHOSITA particularly where the use of AI is common
practice. That panelist also noted that AI might be able to make use of
prior art from fields that humans may not have been expected to find or
use, and that the universe of prior art would expand as AI advances.
Another panelist commented that obviousness is always determined in
view of prior art references and that the extent to which AI
developments should affect the obviousness standard was unclear. After
this June 2022 inaugural event, the Office held several additional AI/
ET Partnership events in 2022 and 2023.\15\
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\12\ Events for the Artificial Intelligence and Emerging
Technologies Partnership, 87 FR 34669 (June 7, 2022).
\13\ A video of the meeting is available at www.uspto.gov/about-us/events/aiet-partnership-series-1-kickoff-uspto-aiet-activities-and-patent-policy.
\14\ A higher level of ordinary skill in the art would more
likely support the conclusion that a PHOSITA would recognize that
the differences between a claimed invention and the prior art are
such that the claimed invention would have been obvious. See, e.g.,
In re GPAC Inc., 57 F.3d 1573 (Fed. Cir. 1995) (GPAC); see also
Section III of this notice.
\15\ See AI and Emerging Technology Partnership engagement and
events web page at www.uspto.gov/initiatives/artificial-intelligence/ai-and-emerging-technology-partnership-engagement-and-events.
---------------------------------------------------------------------------
In February 2023, the USPTO issued an RFC on AI and
inventorship.\16\ This request focused on questions of inventorship,
but it also asked what other areas of focus the USPTO should prioritize
in future engagements. Many commenters indicated that the USPTO should
investigate how AI impacts obviousness determinations and the PHOSITA
assessment.\17\ For example, some commenters stated that an invention
developed with the use of AI should not render that invention obvious
or more likely to be obvious.\18\ Conversely, other commenters
indicated that AI contributions to an invention should be per se
obvious or that the AI contribution should have a rebuttable
presumption of obviousness.\19\ Commenters also indicated that AI has
the potential to generate a vast amount of prior art, which may have an
impact on the Office's anticipation and obviousness determinations.\20\
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\16\ Request for Comments Regarding Artificial Intelligence and
Inventorship, 88 FR 9492 (February 14, 2023) (February 2023 AI RFC).
\17\ Comments in response to the February 2023 AI RFC are
available at www.regulations.gov/docket/PTO-P-2022-0045.
\18\ See, e.g., Comment PTO-P2022-0045-0052 (AUTM).
\19\ See, e.g., Comment PTO-P2022-0045-0057 (Alliance for
Automotive Innovation), and Comment PTO-P2022-0045-0063 (The
Computer & Communications Industry Association and The Public
Innovation Project).
\20\ See, e.g., Comment PTO-P2022-0045-0013 (James Gatto).
---------------------------------------------------------------------------
The increasing power and deployment of AI has the potential to
provide tremendous societal and economic benefits and foster a new wave
of innovation and creativity while also posing novel challenges and
opportunities for IP policy. Based on the feedback that the USPTO has
received from our stakeholders on the importance of AI's impact on
prior art, on the knowledge of a PHOSITA, and on other patentability
considerations, the Office plans to more deeply engage with
stakeholders and is requesting further comments in these areas. This
RFC builds on the USPTO's recent AI-related efforts associated with
Executive Order 14110,\21\ including the ``Inventorship Guidance for
AI-Assisted Inventions'' \22\ published on February 13, 2024.
---------------------------------------------------------------------------
\21\ Executive Order on the Safe, Secure, and Trustworthy
Development and Use of Artificial Intelligence, Executive Order
14110, 88 FR 75191 (November 1, 2023).
\22\ Inventorship Guidance for AI-Assisted Inventions, 89 FR
10043 (February 13, 2024).
---------------------------------------------------------------------------
Section II of this notice provides an overview of prior art
considerations and discusses some concerns relevant to AI-generated
prior art. Section III discusses the current PHOSITA assessment as it
is applied by the USPTO and the courts. Sections II and III are
intended only to provide context for the questions presented in this
notice. This RFC is not a guidance document and does not announce any
new Office practice or procedure. Section IV presents questions to the
public on the impact of AI on prior art and the PHOSITA assessment.
II. Considerations for the Impact of AI on Prior Art
``A claimed invention may be rejected under 35 U.S.C. 102 when the
invention is anticipated (or is `not novel') over a disclosure that is
available as prior art. To reject a claim as anticipated by a [prior
art] reference, the disclosure must teach every element required by the
claim under its broadest reasonable interpretation.'' \23\ Under 35
U.S.C. 102(a)(1), a person is not entitled to a patent if the claimed
invention was disclosed--including being patented; described in a
printed publication; or in public use, on sale, or otherwise available
to the public--before the effective filing date of the claimed
invention (i.e., the disclosure is a ``prior art disclosure''). Under
35 U.S.C. 102(a)(2), a person is not entitled to a patent if ``the
claimed invention was described in a patent issued under [35 U.S.C.
151], or in an application for patent published or deemed published
under [35 U.S.C. 122(b)], in which the patent or application, as the
case may be, names another inventor and was effectively filed before
the effective filing date of the claimed invention.'' A disclosure that
is a prior art reference under 35 U.S.C. 102 may also serve as a basis
for obviousness under 35 U.S.C. 103.\24\
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\23\ Manual of Patent Examining Procedure (MPEP) 2131.
\24\ MPEP 2141.01, subsection I; MPEP 2141.01(a).
---------------------------------------------------------------------------
To qualify as a ``printed publication'' under 35 U.S.C. 102(a)(1),
a prior art reference must have been publicly accessible, i.e.,
``available to the extent that persons interested and ordinarily
skilled in the subject matter or art, exercising reasonable diligence,
can
[[Page 34219]]
locate [the reference].'' \25\ AI may be used to create vast numbers of
disclosures that may have been generated without any human
contribution, supervision, or review. Because a PHOSITA is ``a
hypothetical person who is presumed to have known the relevant art at
the relevant time,'' \26\ the proliferation of AI-generated disclosures
may question the soundness of presuming that a PHOSITA knew of relevant
AI-generated art when the vast amount of AI-generated disclosures was
never reviewed by a human. Further, as suggested by stakeholders, there
is a question whether AI-generated disclosures, especially those with
no human input, review, or validation, should qualify as prior art
disclosures and potentially preclude human-created inventions from
being patented.
---------------------------------------------------------------------------
\25\ MPEP 2128, subsection I (quoting In re Wyer, 655 F.2d 221,
210 USPQ 790 (C.C.P.A. 1981) (quoting I.C.E. Corp. v. Armco Steel
Corp., 250 F. Supp. 738, 743, 148 USPQ 537, 540 (SDNY 1966))).
\26\ MPEP 2141.03, subsection I.
---------------------------------------------------------------------------
Additionally, ``[w]hen the [prior art] reference relied on
expressly anticipates or makes obvious all of the elements of the
claimed invention, the reference is presumed to be operable,''
regardless of the type of prior art (e.g., patent, printed publication,
or other prior art disclosure), and the burden is on the applicant to
rebut the presumption of operability.\27\ The presumption is that a
public disclosure provides a description that enables the public to
make and use the disclosure. The presumption does not (at least
currently) distinguish between who or what made the disclosure, which
prompts the question whether AI-generated disclosures (that have not
been prepared and reviewed by a human) should be afforded the same
rebuttable presumption that they are operable and enabled. In view of
the above issues, the proliferation of AI-generated prior art raises
questions on which the Office seeks input from stakeholders.
---------------------------------------------------------------------------
\27\ MPEP 2121, subsections I and II. Note, however, ``[e]ven if
a reference discloses an inoperative device, it is prior art for all
that it teaches'' and ``may qualify as prior art for the purpose of
determining obviousness under 35 U.S.C. 103.'' MPEP 2121.01,
subsection II.
---------------------------------------------------------------------------
III. Considerations for the Impact of AI on the Knowledge of a PHOSITA
``A patent for a claimed invention may not be obtained . . . if the
differences between the claimed invention and the prior art are such
that the claimed invention as a whole would have been obvious before
the effective filing date of the claimed invention to a person having
ordinary skill in the art to which the claimed invention pertains.''
\28\ Thus, obviousness is to be determined with regard to a
PHOSITA.\29\ As reiterated by the Supreme Court in KSR International
Co. v. Teleflex Inc.\30\ (KSR), obviousness is a question of law based
on underlying factual inquiries established in Graham v. John Deere Co.
(Graham).\31\ The Graham factual inquiries are: (1) determining the
scope and content of the prior art, (2) ascertaining the differences
between the claimed invention and the prior art, (3) resolving the
level of ordinary skill in the art, and (4) evaluating any objective
evidence of nonobviousness.\32\ Once these factual findings are made, a
determination of obviousness should focus on ``what a person of
ordinary skill in the pertinent art would have known at the relevant
time, and on what such a person would have reasonably expected to have
been able to do in view of that knowledge.'' \33\
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\28\ 35 U.S.C. 103 (emphasis added).
\29\ MPEP 2141.
\30\ 550 U.S. 398, 406 (2007).
\31\ 383 U.S. 1, 17-18 (1966). The Office recently published
``Updated Guidance for Making a Proper Determination of
Obviousness'' (89 FR 14449 (February 27, 2024)), which provides a
review of the flexible approach to determining obviousness required
by KSR.
\32\ MPEP 2141, subsection II.
\33\ Id.
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Likewise, a patent ``specification shall contain a written
description of the invention, and of the manner and process of making
and using it, in such full, clear, concise, and exact terms as to
enable any person skilled in the art to which it pertains . . . to make
and use the same.'' \34\ The courts have analyzed written description
and enablement issues from the vantage point of a PHOSITA.\35\ However,
the role of a PHOSITA goes beyond these statutory considerations for
obviousness under 35 U.S.C. 103 and the requirements under 35 U.S.C.
112. For example, claim terms are construed in the manner in which a
PHOSITA would understand them.\36\ Additionally, claims can be
anticipated by prior art inherently if ``the missing descriptive matter
is necessarily present in the thing described in the reference, and
that it would be so recognized by persons of ordinary skill.'' \37\
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\34\ 35 U.S.C. 112(a) (emphasis added).
\35\ MPEP 2163.02 (``An objective standard for determining
compliance with the written description requirement is, `does the
description clearly allow persons of ordinary skill in the art to
recognize that he or she invented what is claimed.' In re Gosteli,
872 F.2d 1008, 1012, 10 USPQ2d 1614, 1618 (Fed. Cir. 1989)''); MPEP
2164.02 (``Allergan, Inc. v. Sandoz Inc., 796 F.3d 1293, 1310, 115
USPQ2d 2012, 2023 (Fed. Cir. 2015) (`Only a sufficient description
enabling a person of ordinary skill in the art to carry out an
invention is needed.')'').
\36\ MPEP 2111.
\37\ MPEP 2131.01, subsection III (citing Continental Can Co. v.
Monsanto Co., 948 F.2d 1264, 1268 (Fed. Cir. 1991)).
---------------------------------------------------------------------------
The Court of Appeals for the Federal Circuit has identified several
factors to consider when determining a PHOSITA's level of skill,
including the type of problems encountered in the art, prior art
solutions to those problems, the rapidity with which innovations are
made, the sophistication of the technology, and the education level of
active workers in the field.\38\ Each case may vary, not every one of
the aforementioned factors may be present, and one or more factors may
predominate the analysis.\39\
---------------------------------------------------------------------------
\38\ MPEP 2141.03, subsection I (citing GPAC, 57 F.3d at 1579).
\39\ Id.
---------------------------------------------------------------------------
Accordingly, it is often critical in a patentability inquiry to
assess the PHOSITA's level of skill in the relevant art,\40\ including
for claim construction, anticipation, obviousness, written description,
and enablement. In view of the above issues, the proliferation of AI as
a tool for a PHOSITA raises questions on which the Office seeks input.
---------------------------------------------------------------------------
\40\ MPEP 2141.03.
---------------------------------------------------------------------------
IV. Questions for Public Comment
The questions enumerated below should not be taken as an indication
that the USPTO has taken a position on or is predisposed to any
particular views. The USPTO welcomes comments from the public on any
issues that are relevant to this topic, and is particularly interested
in answers to the following questions:
A. The Impact of AI on Prior Art
1. In what manner, if any, does 35 U.S.C. 102 presume or require
that a prior art disclosure be authored and/or published by humans? In
what manner, if any, does non-human authorship of a disclosure affect
its availability as prior art under 35 U.S.C. 102?
2. What types of AI-generated disclosures, if any, would be
pertinent to patentability determinations made by the USPTO? How are
such disclosures currently being made available to the public? In what
other ways, if any, should such disclosures be made available to the
public?
3. If a party submits to the Office a printed publication or other
evidence that the party knows was AI-generated, should that party
notify the USPTO of this fact, and if so, how? What duty, if any,
should the party have to determine whether a disclosure was AI-
generated?
4. Should an AI-generated disclosure be treated differently than a
non-AI-
[[Page 34220]]
generated disclosure for prior art purposes? For example:
a. Should the treatment of an AI-generated disclosure as prior art
depend on the extent of human contribution to the AI-generated
disclosure?
b. How should the fact that an AI-generated disclosure could
include incorrect information (e.g., hallucinations) affect its
consideration as a prior art disclosure?
c. How does the fact that a disclosure is AI-generated impact other
prior art considerations, such as operability, enablement, and public
accessibility?
5. At what point, if ever, could the volume of AI-generated prior
art be sufficient to create an undue barrier to the patentability of
inventions? At what point, if ever, could the volume of AI-generated
prior art be sufficient to detract from the public accessibility of
prior art (i.e., if a PHOSITA exercising reasonable diligence may not
be able to locate relevant disclosures)?
B. The Impact of AI on a PHOSITA
6. Does the term ``person'' in the PHOSITA assessment presume or
require that the ``person'' is a natural person, i.e., a human? How, if
at all, does the availability of AI as a tool affect the level of skill
of a PHOSITA as AI becomes more prevalent? For example, how does the
availability of AI affect the analysis of the PHOSITA factors, such as
the rapidity with which innovations are made and the sophistication of
the technology?
7. How, if at all, should the USPTO determine which AI tools are in
common use and whether these tools are presumed to be known and used by
a PHOSITA in a particular art?
8. How, if at all, does the availability to a PHOSITA of AI as a
tool impact:
a. Whether something is well-known or common knowledge in the art?
b. How a PHOSITA would understand the meaning of claim terms?
9. In view of the availability to a PHOSITA of AI as a tool, how,
if at all, is an obviousness determination affected, including when:
a. Determining whether art is analogous to the claimed invention,
given AI's ability to search across art fields? Does the ``analogous''
art standard still make sense in view of AI's capabilities?
b. Determining whether there is a rationale to modify the prior
art, including the example rationales suggested by KSR (MPEP 2143,
subsection I) (e.g., ``obvious to try'') or the scientific principle or
legal precedent rationales (MPEP 2144)?
c. Determining whether the modification yields predictable results
with a reasonable expectation of success (e.g., how to evaluate the
predictability of results in view of the stochasticity (or lack of
predictability) of an AI system)?
d. Evaluating objective indicia of obviousness or nonobviousness
(e.g., commercial success, long felt but unsolved needs, failure of
others, simultaneous invention, unexpected results, copying, etc.)?
10. How, if at all, does the recency of the information used to
train an AI model or that ingested by an AI model impact the PHOSITA
assessment when that assessment may focus on an earlier point in time
(e.g., the effective filing date of the claimed invention for an
application examined under the First-Inventor-to-File provisions of the
America Invents Act)?
11. How, if at all, does the availability to a PHOSITA of AI as a
tool impact the enablement determination under 35 U.S.C. 112(a)?
Specifically, how does it impact the consideration of the In re Wands
factors (MPEP 2164.01(a)) in ascertaining whether the experimentation
required to enable the full scope of the claimed invention is
reasonable or undue?
C. The Implications of AI That Could Require Updated Examination
Guidance and/or Legislative Change
12. What guidance from the USPTO on the impact of AI on prior art
and on the knowledge of a PHOSITA, in connection with patentability
determinations made by the Office, would be helpful?
13. In addition to the considerations discussed above, in what
other ways, if any, does the proliferation of AI impact patentability
determinations made by the Office (e.g., under 35 U.S.C. 101, 102, 103,
112, etc.)?
14. Are there any laws or practices in other countries that
effectively address any of the questions above? If so, please identify
them and explain how they can be adapted to fit within the framework of
U.S. patent law.
15. Should title 35 of the U.S. Code be amended to account for any
of the considerations set forth in this notice, and if so, what
specific amendments do you propose, and why?
Katherine K. Vidal,
Under Secretary of Commerce for Intellectual Property and Director of
the United States Patent and Trademark Office.
[FR Doc. 2024-08969 Filed 4-29-24; 8:45 am]
BILLING CODE 3510-16-P