Experimental Use Exception Request for Comments, 53963-53965 [2024-14164]
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Federal Register / Vol. 89, No. 125 / Friday, June 28, 2024 / Notices
diminishing the effectiveness of the
AIDCP.
As a part of the affirmative finding
process set forth in 50 CFR 216.24(f)(8),
the Assistant Administrator considered
documentary evidence submitted by the
Government of El Salvador and obtained
from the IATTC and determined that El
Salvador met the MMPA’s requirements
to receive a new 5-year affirmative
finding.
After consultation with the
Department of State, the Assistant
Administrator issued a new 5-year
affirmative finding to El Salvador,
allowing the importation into the
United States of yellowfin tuna and
products derived from yellowfin tuna
harvested in the ETP by purse seine
vessels operating under El Salvador’s
jurisdiction or exported from El
Salvador. Issuance of a new 5-year
affirmative finding for El Salvador does
not affect implementation of an
intermediary nation embargo under 50
CFR 216.24(f)(9), which applies to
exports from a nation that exports to the
United States yellowfin tuna or
yellowfin tuna products that was subject
to a ban on importation into the United
States under section 101(a)(2)(B) of the
MMPA, 16 U.S.C. 1371(a)(2)(B).
This new affirmative finding for El
Salvador is for the 5-year period of April
1, 2023, through March 31, 2028, subject
to subsequent annual reviews by NMFS.
Dated: June 14, 2024.
Janet Coit,
Assistant Administrator for Fisheries,
National Marine Fisheries Service.
[FR Doc. 2024–14330 Filed 6–27–24; 8:45 am]
BILLING CODE 3510–22–P
DEPARTMENT OF COMMERCE
Patent and Trademark Office
[Docket No.: PTO–C–2024–0023]
Experimental Use Exception Request
for Comments
United States Patent and
Trademark Office, Department of
Commerce.
ACTION: Notice and request for
comments.
AGENCY:
The United States Patent and
Trademark Office (USPTO), Department
of Commerce, is interested in collecting
the public’s views on the current state
of the common law experimental use
exception and whether legislative action
should be considered to enact a
statutory experimental use exception.
DATES: Written comments must be
received on or before September 26,
2024.
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SUMMARY:
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For reasons of Government
efficiency, comments should be
submitted through the Federal
eRulemaking Portal at https://
www.regulations.gov. To submit
comments via the portal, enter docket
number PTO–C–2024–0023 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 request
for information and click on the
‘‘Comment’’ icon, complete the required
fields, and enter or attach your
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portable document format 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.
Visit the Federal eRulemaking Portal
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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 submit comments by
First-Class Mail or Priority Mail to:
Christian Hannon, Senior Patent
Attorney, Mail Stop OPIA, U.S. Patent
and Trademark Office, P.O. Box 1450,
Alexandria, VA 22313–1450.
FOR FURTHER INFORMATION CONTACT:
Christian Hannon, Senior Patent
Attorney, USPTO, Office of Policy and
International Affairs (OPIA), at 571–
272–7385.
SUPPLEMENTARY INFORMATION: The
USPTO is interested in collecting the
public’s views on the current state of the
common law experimental use
exception and whether legislative action
should be considered to enact a
statutory experimental use exception.
ADDRESSES:
Historical Development of the
Experimental Use Doctrine
The experimental use defense to a
claim of patent infringement was first
introduced in the landmark case
Whittemore v. Cutter.1 The Whittemore
court approved the instruction to the
jury that ‘‘the making of a machine fit
for use, and with a design to use it for
profit, was an infringement’’ of a patent
right.2 In assessing this instruction, the
1 Whittemore v. Cutter, 29 F. Cas. 1120 (C.C.D.
Mass. 1813) (Case No. 17,600).
2 Prior to the enactment of the Patent Act of 1952,
rights conferred by a patent grant gave a patentee
the ‘‘sole and exclusive right and liberty of making,
constructing, using, and vending’’ his or her
invention. Without the written consent of the patent
holder, the accused infringing party was required to
forfeit and pay damages to the patentee. See Patent
Act of 1790, Ch. 7, sec. 1, 1 Stat. 109–112 (April
10, 1970).
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53963
court reasoned that ‘‘it could never have
been the intention of the legislature to
punish a man, who constructed such a
machine merely for philosophical
experiments, or for the purpose of
ascertaining the sufficiency of the
machine to produce its described
effects.’’ 3 Thus, the court looked to the
prospect of profit-making to determine
infringement.4
Subsequent courts affirmed
Whittemore’s rationale, finding that
experimentation is not a defense to
infringement if it creates a benefit for
the accused infringer.5 Thus, in Bonsack
Machine v. Underwood, the court found
that experimentation on a patented
cigarette machine was not experimental
use when the purpose of the experiment
was to show superior properties of the
defendant’s competing product.6 In
Roche Prod. v. Bolar Pharm. Co., the
court found that ‘‘Bolar’s intended
‘experimental’ use is solely for business
reasons and not for amusement, to
satisfy idle curiosity, or for strictly
philosophical inquiry.’’ 7 Notably, the
Roche court stated that it ‘‘cannot
construe the experimental use rule so
broadly as to allow a violation of the
patent laws in the guise of ‘‘scientific
inquiry,’’ when that inquiry has
definite, cognizable, and not
insubstantial commercial purposes.’’ 8
Subsequently, in Embrex v. Service
Engineering Corp., the court denied an
experimental use defense because of the
district court’s determination that the
defendant performed tests ‘‘expressly
for commercial purposes.’’ 9
The U.S. Court of Appeals for the
Federal Circuit revisited the
experimental use exception in Madey v.
Duke University, finding that the district
court ‘‘erred in applying the
experimental use defense.’’ 10 The court
explained that its precedent does not
immunize ‘‘use that is in any way
3 Id.; see also Sawin v. Guild, 21 F. Cas. 554, 554
(C.C.D. Mass. 1813 (No. 12,319)) (stating that
Whittemore held that making must be coupled with
intent to use for profit).
4 Id.
5 Bonsack Mach. Co. v. Underwood, 73 F. 206
(C.C.E.D.N.C. 1896) (holding that ‘‘the making of an
infringing machine merely as an experiment is not
an actionable infringement, but if it is to be used
for the purpose of selling the patent under which
it is made, it is then to be regarded as use for profit,
and a suit will lie for the infringement’’).
6 Id.
7 See Roche Prod. v. Bolar Pharm. Co., 733 F.2d
858, 862 (Fed. Cir. 1984) at 863.
8 Id. This holding was effectively superseded by
the Drug Price Competition and Patent Term
Restoration Act of 1984 (commonly referred to as
the Hatch-Waxman Act and codified at 35 U.S.C.
271(e)(1)).
9 Embrex, Inc. v. Service Engineering Corp., 216
F.3d 1343 (Fed. Cir. 2000) at 1349.
10 Madey v. Duke University, 307 F.3d 1361 (Fed.
Cir. 2002) at 1352.
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53964
Federal Register / Vol. 89, No. 125 / Friday, June 28, 2024 / Notices
commercial in nature’’ or ‘‘any conduct
that is in keeping with the alleged
infringer’s legitimate business,
regardless of commercial
implications.’’ 11 The court concluded,
‘‘regardless of whether a particular
institution or entity is engaged in an
endeavor for commercial gain, so long
as the act is in furtherance of the alleged
infringer’s legitimate business and is not
solely for amusement, to satisfy idle
curiosity, or for strictly philosophical
inquiry, the act does not qualify for the
very narrow and strictly limited
experimental use defense.’’ 12 This
‘‘very narrow and strictly limited
experimental use defense’’ 13 remains
the current state of experimental use
exception jurisprudence in the United
States.
A range of views on the propriety and
scope of the experimental use exception
arose following Madey.14 Some argued
that a narrow exception enhances
innovation by rewarding innovators
with robust patent rights, while others
noted that restricting researcher access
to patented technologies would impede
innovation.15
Previous attempts at codifying the
common law experimental use
exception have been unsuccessful. For
example, section 402 of title IV of the
Patent Competitiveness and
Technological Innovation Act of 1990
(H.R. 5598) proposed a ‘‘research
exemption from patent infringement.’’ 16
Additionally, the Genomic Research and
Diagnostic Accessibility Act of 2002
(H.R. 3967) proposed amending title 35
of the United States Code to ‘‘provide
for noninfringing uses of patents on
genetic sequence information for
purposes of research and genetic
diagnostic testing, and to require public
disclosure of such information in
certain patent applications.’’ 17
Article 30 of the Agreement on TradeRelated Aspects of Intellectual Property
Rights (TRIPS) provides World Trade
Organization members the possibility to
enact exceptions to patent rights as long
as they ‘‘do not unreasonably conflict
with a normal exploitation of the patent
and do not unreasonably prejudice the
legitimate interest of the patent owner,
taking account of the legitimate interests
11 Id.
12 Id.
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13 Id.
14 John R. Thomas, Scientific Research and the
Experimental Use Privilege in Patent Law, CRS
Report No. RL32651 (2004). Available at: https://
sgp.fas.org/crs/RL32651.pdf.
15 Id. at 21.
16 Patent Competitiveness and Technological
Innovation Act of 1990, H.R. 5598, 101st Cong.
(1990).
17 Genomic Research and Diagnostic Accessibility
Act of 2002, H.R. 3967, 107th Cong. (2002).
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of third parties.’’ 18 The United States
has codified a safe harbor provision for
certain infringing uses at 35 U.S.C.
271(e)(1). This ‘‘Bolar’’ exemption, as it
is known, allows for the experimental
use of a patented invention by parties to
collect regulatory approval data for
medical devices or drugs. Other
jurisdictions have experimental use
exceptions providing broader flexibility.
It should be noted that the Plant
Variety Protection Act,19 which
provides Federal intellectual property
rights to developers of new plant
varieties, contains exemptions that
allow for others to use the protected
variety in research and for the breeding
of new varieties.
Experimental Use in Other Jurisdictions
Europe
Many European nations, including
Germany,20 the UK,21 France,22 Spain,23
Italy,24 Switzerland,25 and the
Netherlands 26 have implemented a
statutory experimental use exception for
otherwise infringing uses. Although the
precise application of each of these
national exceptions varies based on
interpretation in national courts,27 they
are each broader than the U.S. common
law exception as they apply to any
experimental purpose.
Asia
Many countries in Asia have statutory
experimental use exceptions. Article
69.1 of Japan’s Patent Law provides a
statutory experimental use exception.28
Japanese courts have interpreted this
18 Agreement on Trade Related Aspects of
Intellectual Property Rights, art. 30, Apr. 15, 1994,
Marrakesh Agreement Establishing the World Trade
Organization, Annex 1C, 1869 U.N.T.S. 401
[hereinafter TRIPS].
19 Public Law 91–577, 84 Stat. 1542.
20 Patentgesetz [Patent Act], Dec. 16, 1980,
Bundesgesetzblatt, Teil I, [BGBl I] at 4074, as
amended Aug. 30, 2021, section 11 No. 2 (Ger.).
21 U.K. Patents Act 1977, (1977) art. 60(5)(b), 37
Current Law 1 (Eng.).
22 French Code of Intellectual Property, L. 613–5.
23 Law 11/1986 of 20 March on Patents. Art.
52(1)(b).
24 Industrial Property Code (Legislative Decree
No. 30 of February 10, 2005, as amended up to Law
No. 102 of July 24, 2023) Art. 68(1)(a) (Italy).
25 Article 9(e) of the Federal Act on Patents for
Inventions, adopted in 2008.
26 Netherlands Patent Act (15 Dec 1994, as
amended) Art. 53(3).
27 See Hans-Rainer Jaenichen and Johann Pitz,
Research Exemption/Experimental Use in the
European Union: Patents Do Not Block the Progress
of Science, Cold Spring Harb. Perspect Med. 2015
Feb (explaining that each law has been interested
with distinct variations). Available at: https://www.
ncbi.nlm.nih.gov/pmc/articles/PMC4315916/#FN4.
28 Tokkyoho [Patent L.], Law No. 121 of Apr. 13,
1959 (Japan), amended by Act No. 33 of Jun. 9, 2018
(Japan), art. 69(1) (‘‘A patent right shall not be
effective against the working of the patented
invention for experimental or research purposes.’’).
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exception to include a Bolar exemption
for certain acts related to submissions
for regulatory approval.29 The Japanese
Bolar exemption applies to clinical
testing not only for generic drugs, but
brand-name drugs as well.30 Similarly,
China’s Patent Law provides an
exception for infringing uses for anyone
that ‘‘uses the relevant patent specially
for the purpose of scientific research
and experimentation.’’ 31 Korea’s patent
law provides that ‘‘[w]orking of [a]
patented invention for the purpose of
research or experiments’’ is not an
infringement.32 Likewise, India’s Patent
Act provides that a patented invention
may be made or used by any person ‘‘for
the purpose merely of experiment or
research including the imparting of
instructions to pupils.’’ 33
Americas
Canada and many jurisdictions in
Latin America have codified
experimental use exceptions. Canadian
patent law provides that common law
rights, inter alia, ‘‘in respect of any use,
manufacture, construction or sale of the
patented invention solely for the
purpose of experiments that relate to the
subject-matter of the patent’’ are
unaffected by the statutory Canadian
Bolar exception.34 Brazil’s patent law
statutorily exempts ‘‘acts carried out by
unauthorized third parties for
experimental purposes, in connection
with scientific or technological studies
or researches’’ from patent
infringement.35 Mexico’s industrial
property law exempts from patent
infringement liability ‘‘scientific or
technological research activities for
purely experimental, testing or teaching
purposes.’’ 36 Likewise, the industrial
property law of the Andean
Community 37 grants an exception for
‘‘acts performed for exclusively
experimental purposes on the subject
29 Ono Pharma. Co., Ltd. v. Kyoto Pharmaceutical
Industries, Ltd., Saikō-Saibansho [Supreme Court]
Apr. 4, 1999, 1998(Ju) 153 (holding that clinical
trials conducted during the patent term for the
regulatory submission of a generic drug should be
considered as ‘‘working of a patented invention for
testing or research’’ as described in Art. 69(1) of the
Patent Law and therefore does not constitute patent
infringement).
30 See X(individual) v. Amgen K.K.; Chiteki-zaisan
kōtō-saiban-sho [Intellectual property high court,
second division] Feb. 9, 2021, 2020 (Ne)10051.
31 Patent Law of the People’s Republic of China
(Dec. 27, 2008), Article 69(4).
32 Korea Patent Act (as amended Jan. 27, 2010),
Art. 96(1).
33 The Patents Act, 1970, Art. 47(3).
34 Canadian Patent Act Art. 55.2(6).
35 Brazil Patent Law No. 9,279 of May 14, 1996;
Art. 43(2).
36 Mexico Industrial Property Law (as amended
June 28, 2010), Art. 22(I).
37 The Andean Community of Nations is made up
of Bolivia, Colombia, Ecuador, and Peru.
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Federal Register / Vol. 89, No. 125 / Friday, June 28, 2024 / Notices
matter of the patented invention’’ and
‘‘acts performed solely for the purposes
of teaching or scientific or academic
research.’’ 38
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Scope of Interest
The USPTO is interested in collecting
the public’s views on the impact of the
experimental use exception in all
technology areas. For example, one
technology area for which greater clarity
around the experimental use exception
may be of interest is the agricultural
industry. In March 2023, the U.S.
Department of Agriculture (USDA)
issued a report, prepared in consultation
with the USPTO, on promoting fair
competition and innovation in regards
to seeds and other agricultural inputs.39
In that report, the USDA and the USPTO
both committed to evaluating ‘‘new
proposals for incentivizing and
protecting innovation in the seed and
agricultural-related space, including the
addition of research or breeders’
exemptions for U.S. utility patents.’’ 40
This work is consistent with the call in
the President’s 2021 Executive Order on
Promoting Competition in the American
Economy. The views submitted in
response to this notice will help in
conducting this evaluation, as well as
evaluating the impact of the
experimental use exception in other
technology areas.
Questions for Public Comment
When responding to the questions,
please identify yourself and your
interest in the U.S. patent system. If
applicable, please indicate whether you
fall within one or more of the following
categories:
(1) Inventors, patent owners, or
investors (e.g., venture capital,
investment bank, fund, etc.);
(2) licensees or users of patented
technology;
(3) entities that represent inventors or
patent owners (e.g., law firms);
(4) recipients of demand letters
concerning alleged patent infringement
or accused infringers in a patent
lawsuit;
(5) entities that represent accused
infringers;
(6) government agencies or officials;
(7) academic or research institutions;
(8) intellectual property organizations
or associations; and
(9) nonprofit organizations or
advocacy groups.
38 Andean Community Decision No. 486 of Sept.
14, 2000, Section 53(b) and (c).
39 Agric. Mktg. Serv., U.S. Dep’t Agric., More and
Better Choices for Farmers: Promoting Fair
Competition and Innovation in Seeds and Other
Agricultural Inputs, at 6 (2023).
40 Id. at 6 (2023).
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Commenters need not respond to
every question and may provide
relevant information even if not
responsive to a particular question.
Unless otherwise specified, the
questions are in reference to the U.S.
and/or to U.S. laws and regulations. The
questions should not be interpreted 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:
1. Please explain how the current
state of U.S. experimental use exception
jurisprudence impacts investment and/
or research and development in any
field of technology, including, but not
limited to: (a) quantum computing; (b)
artificial intelligence; (c) other
computer-related inventions; (d)
agriculture; (e) life sciences (including
prescription drugs and medical
devices); and (f) climate-mitigation
technologies.
2. Do you believe there are any
technologies that are negatively affected
by the current state of experimental use
exception jurisprudence in the United
States? If yes, please identify which
technologies and explain how you
believe they are affected.
3. Please explain what impact, if any,
a statutory experimental use exception
would have on the innovation and
commercialization of new technologies
including with respect to: (a) research
and development; (b) ability to obtain
funding; (c) investment strategy; (d)
licensing of patents and patent
applications; (e) product development;
(f) sales, including downstream and
upstream sales; (g) competition; and (h)
patent enforcement and litigation.
4. Has the current state of
experimental use exception
jurisprudence impacted decisions you
have made with respect to filing,
purchasing, licensing, selling, or
maintaining patent applications and
patents in the United States? If yes,
please explain how.
5. Please explain whether you believe
the United States should adopt a
statutory experimental use exception. In
doing so, please identify your reasons,
including by providing evidence and
data to support your views.
6. Please explain how a statutory
experimental use exception, if any,
should be defined. Please include
specific limitations and restrictions you
believe would be needed to ensure that
patent rights are preserved.
7. Please identify public policy
reasons in support of maintaining the
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53965
status quo or changing the experimental
use exception in the United States.
8. Please provide any additional
recommendations on how best to
enhance and facilitate experimental
research on patented inventions in the
United States.
Katherine K. Vidal,
Under Secretary of Commerce for Intellectual
Property and Director of the United States
Patent and Trademark Office.
[FR Doc. 2024–14164 Filed 6–27–24; 8:45 am]
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[Federal Register Volume 89, Number 125 (Friday, June 28, 2024)]
[Notices]
[Pages 53963-53965]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2024-14164]
-----------------------------------------------------------------------
DEPARTMENT OF COMMERCE
Patent and Trademark Office
[Docket No.: PTO-C-2024-0023]
Experimental Use Exception Request for Comments
AGENCY: United States Patent and Trademark Office, Department of
Commerce.
ACTION: Notice and request for comments.
-----------------------------------------------------------------------
SUMMARY: The United States Patent and Trademark Office (USPTO),
Department of Commerce, is interested in collecting the public's views
on the current state of the common law experimental use exception and
whether legislative action should be considered to enact a statutory
experimental use exception.
DATES: Written comments must be received on or before September 26,
2024.
ADDRESSES: For reasons of Government efficiency, comments should be
submitted through the Federal eRulemaking Portal at https://www.regulations.gov. To submit comments via the portal, enter docket
number PTO-C-2024-0023 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 request for information and
click on 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 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.
Visit the Federal eRulemaking Portal (www.regulations.gov) 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 submit comments by
First-Class Mail or Priority Mail to: Christian Hannon, Senior Patent
Attorney, Mail Stop OPIA, U.S. Patent and Trademark Office, P.O. Box
1450, Alexandria, VA 22313-1450.
FOR FURTHER INFORMATION CONTACT: Christian Hannon, Senior Patent
Attorney, USPTO, Office of Policy and International Affairs (OPIA), at
571-272-7385.
SUPPLEMENTARY INFORMATION: The USPTO is interested in collecting the
public's views on the current state of the common law experimental use
exception and whether legislative action should be considered to enact
a statutory experimental use exception.
Historical Development of the Experimental Use Doctrine
The experimental use defense to a claim of patent infringement was
first introduced in the landmark case Whittemore v. Cutter.\1\ The
Whittemore court approved the instruction to the jury that ``the making
of a machine fit for use, and with a design to use it for profit, was
an infringement'' of a patent right.\2\ In assessing this instruction,
the court reasoned that ``it could never have been the intention of the
legislature to punish a man, who constructed such a machine merely for
philosophical experiments, or for the purpose of ascertaining the
sufficiency of the machine to produce its described effects.'' \3\
Thus, the court looked to the prospect of profit-making to determine
infringement.\4\
---------------------------------------------------------------------------
\1\ Whittemore v. Cutter, 29 F. Cas. 1120 (C.C.D. Mass. 1813)
(Case No. 17,600).
\2\ Prior to the enactment of the Patent Act of 1952, rights
conferred by a patent grant gave a patentee the ``sole and exclusive
right and liberty of making, constructing, using, and vending'' his
or her invention. Without the written consent of the patent holder,
the accused infringing party was required to forfeit and pay damages
to the patentee. See Patent Act of 1790, Ch. 7, sec. 1, 1 Stat. 109-
112 (April 10, 1970).
\3\ Id.; see also Sawin v. Guild, 21 F. Cas. 554, 554 (C.C.D.
Mass. 1813 (No. 12,319)) (stating that Whittemore held that making
must be coupled with intent to use for profit).
\4\ Id.
---------------------------------------------------------------------------
Subsequent courts affirmed Whittemore's rationale, finding that
experimentation is not a defense to infringement if it creates a
benefit for the accused infringer.\5\ Thus, in Bonsack Machine v.
Underwood, the court found that experimentation on a patented cigarette
machine was not experimental use when the purpose of the experiment was
to show superior properties of the defendant's competing product.\6\ In
Roche Prod. v. Bolar Pharm. Co., the court found that ``Bolar's
intended `experimental' use is solely for business reasons and not for
amusement, to satisfy idle curiosity, or for strictly philosophical
inquiry.'' \7\ Notably, the Roche court stated that it ``cannot
construe the experimental use rule so broadly as to allow a violation
of the patent laws in the guise of ``scientific inquiry,'' when that
inquiry has definite, cognizable, and not insubstantial commercial
purposes.'' \8\ Subsequently, in Embrex v. Service Engineering Corp.,
the court denied an experimental use defense because of the district
court's determination that the defendant performed tests ``expressly
for commercial purposes.'' \9\
---------------------------------------------------------------------------
\5\ Bonsack Mach. Co. v. Underwood, 73 F. 206 (C.C.E.D.N.C.
1896) (holding that ``the making of an infringing machine merely as
an experiment is not an actionable infringement, but if it is to be
used for the purpose of selling the patent under which it is made,
it is then to be regarded as use for profit, and a suit will lie for
the infringement'').
\6\ Id.
\7\ See Roche Prod. v. Bolar Pharm. Co., 733 F.2d 858, 862 (Fed.
Cir. 1984) at 863.
\8\ Id. This holding was effectively superseded by the Drug
Price Competition and Patent Term Restoration Act of 1984 (commonly
referred to as the Hatch-Waxman Act and codified at 35 U.S.C.
271(e)(1)).
\9\ Embrex, Inc. v. Service Engineering Corp., 216 F.3d 1343
(Fed. Cir. 2000) at 1349.
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The U.S. Court of Appeals for the Federal Circuit revisited the
experimental use exception in Madey v. Duke University, finding that
the district court ``erred in applying the experimental use defense.''
\10\ The court explained that its precedent does not immunize ``use
that is in any way
[[Page 53964]]
commercial in nature'' or ``any conduct that is in keeping with the
alleged infringer's legitimate business, regardless of commercial
implications.'' \11\ The court concluded, ``regardless of whether a
particular institution or entity is engaged in an endeavor for
commercial gain, so long as the act is in furtherance of the alleged
infringer's legitimate business and is not solely for amusement, to
satisfy idle curiosity, or for strictly philosophical inquiry, the act
does not qualify for the very narrow and strictly limited experimental
use defense.'' \12\ This ``very narrow and strictly limited
experimental use defense'' \13\ remains the current state of
experimental use exception jurisprudence in the United States.
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\10\ Madey v. Duke University, 307 F.3d 1361 (Fed. Cir. 2002) at
1352.
\11\ Id.
\12\ Id.
\13\ Id.
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A range of views on the propriety and scope of the experimental use
exception arose following Madey.\14\ Some argued that a narrow
exception enhances innovation by rewarding innovators with robust
patent rights, while others noted that restricting researcher access to
patented technologies would impede innovation.\15\
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\14\ John R. Thomas, Scientific Research and the Experimental
Use Privilege in Patent Law, CRS Report No. RL32651 (2004).
Available at: https://sgp.fas.org/crs/RL32651.pdf.
\15\ Id. at 21.
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Previous attempts at codifying the common law experimental use
exception have been unsuccessful. For example, section 402 of title IV
of the Patent Competitiveness and Technological Innovation Act of 1990
(H.R. 5598) proposed a ``research exemption from patent infringement.''
\16\ Additionally, the Genomic Research and Diagnostic Accessibility
Act of 2002 (H.R. 3967) proposed amending title 35 of the United States
Code to ``provide for noninfringing uses of patents on genetic sequence
information for purposes of research and genetic diagnostic testing,
and to require public disclosure of such information in certain patent
applications.'' \17\
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\16\ Patent Competitiveness and Technological Innovation Act of
1990, H.R. 5598, 101st Cong. (1990).
\17\ Genomic Research and Diagnostic Accessibility Act of 2002,
H.R. 3967, 107th Cong. (2002).
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Article 30 of the Agreement on Trade-Related Aspects of
Intellectual Property Rights (TRIPS) provides World Trade Organization
members the possibility to enact exceptions to patent rights as long as
they ``do not unreasonably conflict with a normal exploitation of the
patent and do not unreasonably prejudice the legitimate interest of the
patent owner, taking account of the legitimate interests of third
parties.'' \18\ The United States has codified a safe harbor provision
for certain infringing uses at 35 U.S.C. 271(e)(1). This ``Bolar''
exemption, as it is known, allows for the experimental use of a
patented invention by parties to collect regulatory approval data for
medical devices or drugs. Other jurisdictions have experimental use
exceptions providing broader flexibility.
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\18\ Agreement on Trade Related Aspects of Intellectual Property
Rights, art. 30, Apr. 15, 1994, Marrakesh Agreement Establishing the
World Trade Organization, Annex 1C, 1869 U.N.T.S. 401 [hereinafter
TRIPS].
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It should be noted that the Plant Variety Protection Act,\19\ which
provides Federal intellectual property rights to developers of new
plant varieties, contains exemptions that allow for others to use the
protected variety in research and for the breeding of new varieties.
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\19\ Public Law 91-577, 84 Stat. 1542.
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Experimental Use in Other Jurisdictions
Europe
Many European nations, including Germany,\20\ the UK,\21\
France,\22\ Spain,\23\ Italy,\24\ Switzerland,\25\ and the Netherlands
\26\ have implemented a statutory experimental use exception for
otherwise infringing uses. Although the precise application of each of
these national exceptions varies based on interpretation in national
courts,\27\ they are each broader than the U.S. common law exception as
they apply to any experimental purpose.
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\20\ Patentgesetz [Patent Act], Dec. 16, 1980,
Bundesgesetzblatt, Teil I, [BGBl I] at 4074, as amended Aug. 30,
2021, section 11 No. 2 (Ger.).
\21\ U.K. Patents Act 1977, (1977) art. 60(5)(b), 37 Current Law
1 (Eng.).
\22\ French Code of Intellectual Property, L. 613-5.
\23\ Law 11/1986 of 20 March on Patents. Art. 52(1)(b).
\24\ Industrial Property Code (Legislative Decree No. 30 of
February 10, 2005, as amended up to Law No. 102 of July 24, 2023)
Art. 68(1)(a) (Italy).
\25\ Article 9(e) of the Federal Act on Patents for Inventions,
adopted in 2008.
\26\ Netherlands Patent Act (15 Dec 1994, as amended) Art.
53(3).
\27\ See Hans-Rainer Jaenichen and Johann Pitz, Research
Exemption/Experimental Use in the European Union: Patents Do Not
Block the Progress of Science, Cold Spring Harb. Perspect Med. 2015
Feb (explaining that each law has been interested with distinct
variations). Available at: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4315916/#FN4.
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Asia
Many countries in Asia have statutory experimental use exceptions.
Article 69.1 of Japan's Patent Law provides a statutory experimental
use exception.\28\ Japanese courts have interpreted this exception to
include a Bolar exemption for certain acts related to submissions for
regulatory approval.\29\ The Japanese Bolar exemption applies to
clinical testing not only for generic drugs, but brand-name drugs as
well.\30\ Similarly, China's Patent Law provides an exception for
infringing uses for anyone that ``uses the relevant patent specially
for the purpose of scientific research and experimentation.'' \31\
Korea's patent law provides that ``[w]orking of [a] patented invention
for the purpose of research or experiments'' is not an
infringement.\32\ Likewise, India's Patent Act provides that a patented
invention may be made or used by any person ``for the purpose merely of
experiment or research including the imparting of instructions to
pupils.'' \33\
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\28\ Tokkyoho [Patent L.], Law No. 121 of Apr. 13, 1959 (Japan),
amended by Act No. 33 of Jun. 9, 2018 (Japan), art. 69(1) (``A
patent right shall not be effective against the working of the
patented invention for experimental or research purposes.'').
\29\ Ono Pharma. Co., Ltd. v. Kyoto Pharmaceutical Industries,
Ltd., Saik[omacr]-Saibansho [Supreme Court] Apr. 4, 1999, 1998(Ju)
153 (holding that clinical trials conducted during the patent term
for the regulatory submission of a generic drug should be considered
as ``working of a patented invention for testing or research'' as
described in Art. 69(1) of the Patent Law and therefore does not
constitute patent infringement).
\30\ See X(individual) v. Amgen K.K.; Chiteki-zaisan
k[omacr]t[omacr]-saiban-sho [Intellectual property high court,
second division] Feb. 9, 2021, 2020 (Ne)10051.
\31\ Patent Law of the People's Republic of China (Dec. 27,
2008), Article 69(4).
\32\ Korea Patent Act (as amended Jan. 27, 2010), Art. 96(1).
\33\ The Patents Act, 1970, Art. 47(3).
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Americas
Canada and many jurisdictions in Latin America have codified
experimental use exceptions. Canadian patent law provides that common
law rights, inter alia, ``in respect of any use, manufacture,
construction or sale of the patented invention solely for the purpose
of experiments that relate to the subject-matter of the patent'' are
unaffected by the statutory Canadian Bolar exception.\34\ Brazil's
patent law statutorily exempts ``acts carried out by unauthorized third
parties for experimental purposes, in connection with scientific or
technological studies or researches'' from patent infringement.\35\
Mexico's industrial property law exempts from patent infringement
liability ``scientific or technological research activities for purely
experimental, testing or teaching purposes.'' \36\ Likewise, the
industrial property law of the Andean Community \37\ grants an
exception for ``acts performed for exclusively experimental purposes on
the subject
[[Page 53965]]
matter of the patented invention'' and ``acts performed solely for the
purposes of teaching or scientific or academic research.'' \38\
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\34\ Canadian Patent Act Art. 55.2(6).
\35\ Brazil Patent Law No. 9,279 of May 14, 1996; Art. 43(2).
\36\ Mexico Industrial Property Law (as amended June 28, 2010),
Art. 22(I).
\37\ The Andean Community of Nations is made up of Bolivia,
Colombia, Ecuador, and Peru.
\38\ Andean Community Decision No. 486 of Sept. 14, 2000,
Section 53(b) and (c).
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Scope of Interest
The USPTO is interested in collecting the public's views on the
impact of the experimental use exception in all technology areas. For
example, one technology area for which greater clarity around the
experimental use exception may be of interest is the agricultural
industry. In March 2023, the U.S. Department of Agriculture (USDA)
issued a report, prepared in consultation with the USPTO, on promoting
fair competition and innovation in regards to seeds and other
agricultural inputs.\39\ In that report, the USDA and the USPTO both
committed to evaluating ``new proposals for incentivizing and
protecting innovation in the seed and agricultural-related space,
including the addition of research or breeders' exemptions for U.S.
utility patents.'' \40\ This work is consistent with the call in the
President's 2021 Executive Order on Promoting Competition in the
American Economy. The views submitted in response to this notice will
help in conducting this evaluation, as well as evaluating the impact of
the experimental use exception in other technology areas.
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\39\ Agric. Mktg. Serv., U.S. Dep't Agric., More and Better
Choices for Farmers: Promoting Fair Competition and Innovation in
Seeds and Other Agricultural Inputs, at 6 (2023).
\40\ Id. at 6 (2023).
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Questions for Public Comment
When responding to the questions, please identify yourself and your
interest in the U.S. patent system. If applicable, please indicate
whether you fall within one or more of the following categories:
(1) Inventors, patent owners, or investors (e.g., venture capital,
investment bank, fund, etc.);
(2) licensees or users of patented technology;
(3) entities that represent inventors or patent owners (e.g., law
firms);
(4) recipients of demand letters concerning alleged patent
infringement or accused infringers in a patent lawsuit;
(5) entities that represent accused infringers;
(6) government agencies or officials;
(7) academic or research institutions;
(8) intellectual property organizations or associations; and
(9) nonprofit organizations or advocacy groups.
Commenters need not respond to every question and may provide
relevant information even if not responsive to a particular question.
Unless otherwise specified, the questions are in reference to the U.S.
and/or to U.S. laws and regulations. The questions should not be
interpreted 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:
1. Please explain how the current state of U.S. experimental use
exception jurisprudence impacts investment and/or research and
development in any field of technology, including, but not limited to:
(a) quantum computing; (b) artificial intelligence; (c) other computer-
related inventions; (d) agriculture; (e) life sciences (including
prescription drugs and medical devices); and (f) climate-mitigation
technologies.
2. Do you believe there are any technologies that are negatively
affected by the current state of experimental use exception
jurisprudence in the United States? If yes, please identify which
technologies and explain how you believe they are affected.
3. Please explain what impact, if any, a statutory experimental use
exception would have on the innovation and commercialization of new
technologies including with respect to: (a) research and development;
(b) ability to obtain funding; (c) investment strategy; (d) licensing
of patents and patent applications; (e) product development; (f) sales,
including downstream and upstream sales; (g) competition; and (h)
patent enforcement and litigation.
4. Has the current state of experimental use exception
jurisprudence impacted decisions you have made with respect to filing,
purchasing, licensing, selling, or maintaining patent applications and
patents in the United States? If yes, please explain how.
5. Please explain whether you believe the United States should
adopt a statutory experimental use exception. In doing so, please
identify your reasons, including by providing evidence and data to
support your views.
6. Please explain how a statutory experimental use exception, if
any, should be defined. Please include specific limitations and
restrictions you believe would be needed to ensure that patent rights
are preserved.
7. Please identify public policy reasons in support of maintaining
the status quo or changing the experimental use exception in the United
States.
8. Please provide any additional recommendations on how best to
enhance and facilitate experimental research on patented inventions in
the United States.
Katherine K. Vidal,
Under Secretary of Commerce for Intellectual Property and Director of
the United States Patent and Trademark Office.
[FR Doc. 2024-14164 Filed 6-27-24; 8:45 am]
BILLING CODE 3510-16-P