Latest Technological Advancements and Innovations: Their Coexistence with the Current Patent Laws and Systems

I. Introduction

The influence of Intellectual Property Rights is widespread in the modern economy. Intellectual Property Rights act as effective instruments which guarantee protection of the investment, time, efforts and money of a creator or an inventor as they accord exclusive rights to the creator or inventor to realize the full potential of his/her creation. Along with the economic development of the country, it also induces a healthy environment for the production of new ideas and creations. And this, in turn, gives a boost to the very objective of Intellectual Property Rights- ‘promotion and encouragement of creativity’.

In today’s day, technological advancement has seen proliferating growth. There are novel inventions which infiltrate the market on a day to day basis. Technological advancement plays a very crucial role in helping countries boost their economy. Cross border advancement in this field also helps maintain their foreign policy and helps build good relations.² Over time, with increasing human wants, there has been a drastic depletion in natural resources. But this focus has been overtaken by the technological advancement and innovations. Which is only fair, since the these advancements and innovations are the saving grace for preserving the depleting natural resources. Development of new techniques creates the space to make the most out of minimal amount of resources.

At the same time, such technological development has posed a new set of issues for intellectual property systems. The Patent Law system in particular. Since these advancements carry high levels of technical factors and processes, the pressure to afford better and a higher degree of protection arises. Most intellectual property laws are accommodative of technological change, patent law and copyright law in particular. Traditionally, the pre-existing legal framework has been sufficient to safeguard new technologies. But in the recent times, with the development of various computer programmes and new advancement in semiconductor chips, etc. the the existing legal framework has taken a set back. These two technologies, although very economically valuable, do not fit into the copyright regime or the patent regime. Such is the example of USA, where these two technologies faces problems in acquiring in protection since the American law states that a semiconductor or computer software cannot be protected under patent and copyright law simultaneously.³ A similar issue arises when there are “incremental developments” in an already existing innovation. India’s patent law, for example, limits protection for such incremental development.⁴ New innovations may not always be ones which have been developed from scratch. A common example of this, with regard to patents is secondary pharmaceutical patents. Secondary pharmaceutical patents are a topic of debate when it comes to granting patent protection.⁵ Not granting protection to some of these secondary pharmaceutical patents would be a set back in the medical field and would also be detrimental in terms of public health and interest.

The above mentioned leads us to the question- whether there is a pressing need for developing an alternative patent or copyright system for protecting such technologies which are beyond the scope of being protected under one Intellectual Property system. There arises an inherent need to strengthen the Intellectual Property regime, especially the Patent Law system in order to delve further into technological advancements and upcoming innovations.

(A) Research Problem

With the latest development in technology, there have been certain doubts on the protection front with regard to legal instruments that are already in place. Relatively, developed nations and certain developing nations have an upper hand since they have the means and resources ready at disposal to deal with latest technological advancements. On the contrary, there are several nations who have not seen much technological advancement or innovations due to factors like their geographical location or isolation from the global culture. There is an inherent need to transfer technologies which already exist to these nations since these nations are the ones which have higher population, but their low per capita income is very low.⁶ In such cases, patent systems and their efficacious functioning play a crucial role with regard to gaining access to technology in the present era. This is inclusive of the patent systems at the national, as well as international level.

Quantification of the relationship between advancement in technology and patent systems may be difficult. With progress of time, newer technologies and innovations are entering the market and many of these are beyond the set patentable subject matter. There is ambiguity with regard to patent protection for plant varieties, animal breeds, etc. and these are often not included under patentable subject matter even though they should be granted protection.

In today’s era, it is of utmost important to have uniform regional and international patent regimes in order to not exclude upcoming technologies from the ambit of patent protection. In the case where such technological advancements are excluded from patentable subject matter, it could be detrimental with respect to public interest. Since many of these technologies could potentially be breakthroughs in their own field. The unaccomodative nature of the existing patent systems is a potential threat to newer technologies and innovations.

There are instances where one innovation or technological advancement can afford protection under more than one intellectual property law system. There is a pressing need for developing an alternative patent system or any other intellectual property system for protecting newer technologies which are beyond the scope of being protected under one Intellectual Property Law system. There arises an inherent need to strengthen the Intellectual Property regime, especially the Patent Law system in order to delve further into technological advancements and upcoming innovations.

(B) Scope and Limitation

The study will cover the current scenario of latest technological advancements and innovations and their relationship with the existing patent systems. A brief will be given about the he current international patent systems which have been established to protect inventions and innovations. The scope of the study extends to analyse if these systems are in a position to accommodate new technologies and innovations which do not fall under one intellectual property system per se and are in a position to obtain protection under more than one intellectual property system.

Latest technological advancements and innovations will also be studied in depth and their correlation with the current patent system will be analysed. The study will also be inclusive of a comparison of Patent Systems in developed and developing/ third world nations. The same will also cover the trends in technological developments in such countries. The study will be structured in a way so as to understand whether the Patent Systems, both national and international ones, are flexible or rigid when it comes to including newer technologies.

The study limits its scope to the study of patents and the patent system. The topic of copyrights will be briefly touched upon while elucidating certain new technologies which have the potential to obtain protection under the copyright regime as well as the patent regime. Apart from this, no other intellectual property will be dealt with under this study.

II. Current international patent system for protection of new technological advancements

The concept of patents and patent protection is one which has a long drawn juridical history. Patents are generally defined as “ government grant of the exclusive rights to make, use, and sell the substance of a recent invention. The life or period of a patent is limited and starts when a patent document is issued by the government.”⁷ A patent can be perceived as an “open letter addressed to the public”⁸ in order to convey that the inventor of that particular patent has exclusive ownership and rights over it.

The history of granting patent protection sees its traces back to the 1400s in Florence, Italy.⁹ But, it is generally assumed that a proper patent system originated during the British industrial revolution period and till date, it has been one of the most illustrious accomplishment in the field of intellectual property since it is this system that helped maintain the foundation of the industrialised world. With time, there have been set standards which need to be met in order to afford patent protection viz. the patent must have inventiveness, it must be a novel invention and it must show industrial applicability.

There have been distinct changes in in various patent systems across the globe with respect to the protection period of a patent. Various countries have a varied history with regard to their patent system and the granting of patent rights. With the evolution of time, apart from having individual patent systems, in each country, there has been a shift to a platform which is labelled as the “International Patent System”.

While every country has it’s own Patent System in place, which is governed by national patent laws, there is an International Patent System established by the World Intellectual Property Organization (WIPO). This international patent system is called the Patent Cooperation Treaty or PCT and it was established in the year 1978. PCT is a multilateral patent treaty and currently, has 152 contracting states and this Treaty is one which allows the applicant to seek patent protection for their invention, simultaneously, in these contracting states.¹⁰ While PCT serves as an international platform for multi-jurisdictional patent protection, the applicants will have to apply through their national patent office, nevertheless. This international patent system has not only created a uniform and facile system for international patent application, but, it has aided in disseminating the need for protection of intellectual property. PCT has set an excellent example when it comes to representation of international cooperation among various countries across the globe and the governmental organisations involved at a national level.

(A) Framework of PCT

After the Paris Convention for Protection of Industrial Property (1883),¹¹ the Patent Cooperation Treaty is the first treaty which has a sufficiently tight-knit legislative framework. The PCT has fixed regulations and administrative instructions which are strictly adhered to when it comes to regulating communication between WIPO, IP offices at national levels and authorities.¹² Further, there are a number of Intellectual Property Offices which serve as “PCT International Searching and Preliminary Examining Authorities” for which guidelines¹³ have been drawn out and regulated in the form of twelve bilateral agreements. Lastly, there are a set of responsibilities the national offices have been entrusted with and the same are governed by the “PCT Receiving Office Guidelines”.¹⁴

Under these bilateral agreements and the Treaty, the “PCT Union Assembly”¹⁵ is the principal body. Further, the Contracting States together form the “Union”.¹⁶ The Union is entrusted with the responsibility to realize the objectives that have been set forth by the Union itself. The Union has the leeway to fulfil these objectives by instituting other bodies. The “Working Group on Reform of the PCT”¹⁷ and the “Committee on Reform of the PCT”¹⁸ are two examples of such bodies. Further due to the need to update the guidelines with regard to International Search and Preliminary Examination, WIPO has set up the “Meeting of International Authorities” in order to update these guidelines, as and when required.

(B) Procedure Under PCT

The Patent Cooperation Treaty affords patent protection only to patents, utility models, etc. The process of granting such patent protection is two-fold. The patent application goes through the international phase first, and then through the national phase. In the international phase, there are four steps which the applicant has to undergo viz. (a) the application has to filed and processed; (b) it has to pass the international search; (c) then it gets published on PATENTSCOPE; (d) following which the application undergoes an international preliminary examination.

Once the above mentioned steps have been completed, the application moves into the National Phase. At this stage, the applicant can designate the nations in the which they want to pursue their application and can obtain protection in these nations. However, the final decision on whether or not to grant patent protection to a particular invention is at the discretion of national offices. These offices are not bound to grant protection solely owing to the fact that the application has passed the international phase.

(C) PCT and Changing Trends

WIPO and the Contracting States to the Patent Cooperation Treaty have been cognizant of the possibility to satisfy the need for change. The PCT highlights the significance to maintain the PCT system and the predictability of the procedure.¹⁹ It is, therefore, deemed necessary to adhere to and stand by the Treaty and the Regulations related to it. The PCT has made it essential for International Authorities, National Offices and WIPO to take into consideration the evolution and trends of technology. It has also made it necessary for these authorities to be mindful of the shift in trends with respect to the applications, their filing and strategies related to their prosecution so as to maintain the smooth functioning of the PCT system.

III. New technologies and their adaptability

There has been an exponential growth in the field of patents over the past few decades. Newer and much more advanced technologies have taken the forefront in improving human life and such technologies have also had an impact on the economy. Such technologies are inclusive of the developments related to biotechnology, semiconductors, computer programs, human genes, 3D printing, integrated information networks, etc. With this development and interdependence of technologies, and also due to fragmented propriety knowledge, a sense of apprehensiveness has emerged towards the difficulty in innovating. At the same time, questions have been raised about the whether such technologies and their commercialisation is manacled due to patents.²⁰

(A) Relationship between Emerging Technology and Patents

The development of gene editing, nanotechnology, synthetic biology, etc have raised concerns about the frontier of general human nature and its propinquity with technology and science. These technological advancements have the power to change altogether the way humans are defined, anthropologically. But, there are ethical concerns which have been raised with regard to patenting such technologies.

In Europe, the patent system is such that it can inhibit patent protection for a certain invention if such invention is flouting the general ethical norms and standards that have been prevalent in perpetuity. This rule is known as “ordre public”.²¹ This rule formulated by the European Patent Office (EPO) stands to be problematic since (a) it gives arbitrary power to the EPO to determine which constitutes as ethical or moral when it comes to technology; (b) it is disputable whether the signatories had the intention to vest such autonomous power to define the ethicality of technology in the hands of the EPO.

In general, newer technologies are of a two fold nature. They have the ability to provide a myriad of benefits to humans but, on the other hand, questions can be raised about the ethicality of the innovation. However, as is the case of Europe, ethics and morals being an impediment to obtaining patent protection is dubious. From a legal point of view, the main focus of granting patent protection should be on the fulfilment of the patentability criteria and the function of the innovation.

(B) Human Augmentation

Human Augmentation also known as Human Enhancement is defined as “..the process of positively augmenting our abilities, permanently or temporarily. It includes any technology that expands or positively alters our capabilities or appearance: drugs, hormones, implants, genetic engineering or some surgeries.”²² Essentially, human augmentation technology is such that it can enhance and/or modify an individual’s inherent abilities or traits. There are various upcoming human augmentation technologies like 3D bioprinting, nanotechnology, neuronal implants, genetic engineering, etc. Although these technologies are of a game-changing nature, they are highly debated from an ethical point of view.

Patenting of human augmentation technologies has a strong opposition in Europe due to order public concerns. The patentability of such technology is contentious owing to the fact that these technologies become a part of the body once applied, thereby linking to the individual’s identity. Thus, raising questions about patenting a part of the body. This is highly debated in Europe owing to the provisions under the “European Patent Convention (EPC)²³ and the “Biotechnology Directive”²⁴. These Directives have laid down a dense set of rules which make it difficult to patent technological advancements which are in close proximity to any living matter, inclusive of humans.

Contrary to the European Patent System, the American Patent System has a relatively broader approach to patenting to human augmentation technologies. In the case of Diamond v. Chakrabarty,²⁵ the US Supreme Court was of the opinion that “anything under the sun made by man” is patentable subject matter. But this was not inclusive of human beings, leaving room for debate on whether such augmented technology eventually becomes are part of the human body thereby making it unfit for patent protection.

In India, the patent filing procedures are stringent and the provisions are dense, making it difficult to attain patent protection for biotechnological development. Under the Patent Act of 1970, patentable subject matters constitutes that matter which is excluded under Section 3 of the Act.²⁶ Like Art. 53(a) of the EPC,²⁷ the Indian Patent Act has an equivalent section, Section 3(b) which defines inventions that are contrary to public morality, thereby excluding such inventions from patent protection. Further, the Act also excludes “discoveries made in relation to living things or non-living substances occurring in nature”.²⁸ The Act also goes on exclude “methods of treatment” such as surgical methods, curative methods, prophylactic methods, etc.²⁹ Although, these provisions under the Patent Act provide an extensive list of what does not constitute as patentable subject matter, it does not give enough clarity about what can be patented thereby making it vague and uncertain for human augmentation technologies due to complexity of their nature.

(C) Artificial Intelligence

With a meld of engineering and science, the field of Artificial Intelligence (AI) has indicated immense development and advancement. By definition, “Artificial Intelligence AI refers to the ability of a computer or a computer operated robot to perform tasks that are generally associated with humans, such as reasoning or learning from past experiences.”³⁰ With the evolution of this technology, we are witnessing the use of AI on a daily basis in the form of voice assistants, chatbots, etc.

AI has the power and capability to take over professions which involve human effort. It even has the ability to take over the field of Intellectual Property, when it comes to granting protection. There is a great deal of trust that needs to be placed on AI when it comes to data that has been fed to train the AI. Also, the possibility of error on the part of AI is undeniable and the same could be due to a number of reasons, for ex. A fault in programming or the wrong data being fed to the AI thereby resulting in an incorrect outcome.

When it comes to the patentability aspect, AI is patentable subject matter. But, there is a lack of clear guidelines from patent offices across many countries. Artificial Intelligence stands on two pillars viz. Deep Learning and Machine Learning. This is usually done via a system of algorithms that help the AI technology carry out the intended task. But, in many jurisdictions across the globe, algorithms are excluded from patentable subject matter.

In the US, AI technology is considered to be the equivalent of algorithms and mathematical models. The same is not eligible for patent protection.³¹ The only scenario in which this changes is where the algorithm is associated to practical association. In Europe, in the guidelines related to AI which have been laid down by the European Patent Office (EPO), Artificial Intelligence is considered to fall under the category of “computer related inventions”. There is a specific requirement that needs to be fulfilled in order to obtain protection for AI related inventions. This requirement is that of the AI having a specific technical purpose. Which means that the AI invention must be developed for a specific use and it must exhibit and explicitly specify the technical effect when the algorithm is use. When compared to the patent system in the US, the European Patent has a similar requirement of there being an interaction between the algorithm and the hardware. In India, AI is governed by Computer-Related Inventions (CRIs) Guidelines.³² excludes algorithms and software/computer programme from attaining patent protection. The same is excluded by the Patent Act, 1970 under Section 3.³³ But, in order to surpass these exclusions, the AI invention’s algorithm or mathematical model must be accompanied with a physical construction when it is mentioned in the claims of a patent application.

(D) Software Implemented Inventions

According to the European Patent Office, “A computer-implemented invention (CII) is one which involves the use of a computer, computer network or other programmable apparatus, where one or more features are realised wholly or partly by means of a computer program.”³⁴ in today’s day, the basis of innovation is no longer restricted to physical objects only. Innovation has taken an inclination towards software from hardware.³⁵ Inspite of this shift, a number of jurisdictions do not grant patent protection to software-related inventions, even now.

In Europe, when Articles 2(c)³⁶ and 3³⁷ are read together with Article 27 of the Trips Agreement³⁸ It is clear that the primary requirement is that the computer program must be technical and the instrument through which it was recorded is immaterial. As long as the computer program is technical, it is patentable. Patent protection for software implemented innovation in the US is restricted to those which are available on “recordable media”. This does not include within its ambit computer programs themselves.³⁹ The US Patent System has still not been able to lay down clear guidelines with regard to patentability of software implemented innovations. In contrast to he the Patent Systems of the US and Europe, the Patent System in Japan has expressly listed computer or software programs under its list patentable subject matter. Article 2(3)(i)⁴⁰ mentions that in order for a computer program to be patentable, is must be a “creation of technical ideas utilizing the law of nature”. Here, there needs to be a interdependent functioning of the hardware and software.

(E) 3D Printing Technology

Three Dimensional Printing or 3D Printing is also referred to as “Rapid Modeling Technology”, “Rapid Manufacturing Technology” or “Additive Manufacturing Technology”. 3D printing relies mainly on “Computer-Aided Design” (CAD) technology. The printer produces 3D printed products using this CAD technology-based digits files. There are five essential elements which form the foundation of this technology viz. artificial intelligence, computer software, new material (such as resin, metal powder, etc.), manufacturing method and internet.⁴¹ 3D printings technology allows consumers to print any product they desire, irrespective of whether or not they have consent from the owner of that product. In the process of 3D printing, the technical functions of the technology are protected by Patent Laws.

The current IP Regime is such that it is adequate to protect various aspects of 3D under copyright laws, patent laws and design laws. The 3D printed object is one which needs evaluation. There could be a case wherein an individual prints a product that has already been patented thereby encouraging the counterfeiting of products. But, there are certain national laws which state that if a certain patented product is produced by an individual in private for non-commercial purposes, it does not affect the exclusive rights of the patent holder. The same has been iterated under Article 30 of the TRIPS Agreement which states that, those countries which are members to this Agreement “may provide limited exceptions to the exclusive rights conferred by a patent”. This obstacle is one which cannot be tracked since individuals can print anything they desire in private. Further, if the printer fulfils all the criteria for patentability, it can seek patent protection under national patent laws or even via the international patent system.

IV. Patent systems in developed and developing/underdeveloped nations

Generally, there is an evident correlation between the nature and stability of a society and the kinds of technology produced in such a society.⁴² Post the Industrial Revolution, there have two extremes with respect to the technological development of societies. There are some which exponential technological growth and prosperity, whereas, there were some societies which saw very little or no technological development after the Industrial Revolution. Those nations which grew technological also saw a significant development in their economy thereby getting the label of developed nations. On the contrary, those nations which did not develop technologically and those who were isolated from knowledge related to technological development continued to rely on manual/hard labour, ingenuity, etc. in order to sustain. This led to very minimal development in their economy thereby getting labeled as a “developing nation” or and “underdeveloped/third world nation”.

This implies that there is a pressing need to transfer technologies which already exist to these nations since these nations are the ones which have higher population, but their low per capita income is very low.⁴³ In such cases, patent systems and their efficacious functioning play a crucial role with regard to gaining access to technology in the present era. This is inclusive of the patent systems at the national, as well as international level.

Quantification of the relationship between advancement in technology and patent systems may be difficult. The very basis of patent protection is the incentive to innovate and to make such innovations available to the public for the better and development of others in the society. To inculcate this culture, it is important to comprehend the state of patent systems in developed and developing/third world countries.

(A) Scenario in Developing/Third World Nations

Ever since such nations were freed from the shackles of colonialism, they have been granting patent protection, primarily, to foreign ventures and they continue to do the same till date. With the continuation of this trend, there remains no scope for developing an third world countries to develop their technology or strengthen their patent system. This also implies that, developed nations will benefit in this process which will lead to them strengthening their patent systems further.

The participation in the International Patent System also plays a pivotal role in determining the fate of such technologically handicapped nations. The effect of participation on one developed nation in the international patent system is equivalent to the collective effect on these developing or third world nations. The interdependence of developing and third world nations with developed nations has been precisely summed up by the late Stephen P. Ladas, an IP law pioneer and author as follows-

“Failure to extend the benefits of technology and science to large parts of the world is not only morally wrong, but in the long run it denies to the total system its ultimate fulfilment. Prosperity like peace is indivisible. The accelerated pace of the West's own economic progress could be nullified by the failure of the rise in the standard of living of the largest part of the world.”⁴⁴

At an international level, with developing and third world countries participating in the international patent system, there must be an understanding between such countries and developed nations for the articulation of unified and more inclusive policy for the upliftment for the developing and third world nations. There is an inherent need for the reconstruction of the intellectual property system in such nations since the current system has detrimental effects on these nations.

Another step that needs to be taken is the transfer of technology from developed nations to the ones in need. In order to effectuate this, there needs to be a substantial transfers via cooperation at an international level. But, the developing and third world nations also need to take it upon themselves to adopt consistent regional practices. Further, such nations must tae steps to involve themselves in various international intellectual property treaties and organisations since these treaties and organisations are the medium through which developed nations function. Such participation will provide a uniform platform for developed nations to transfer their technology.

V. Conclusion

Patents play a crucial role in the development and process of technological advancement and innovation. After getting an insight into the functioning of patent systems at a national and international level, it can be understood that technological advancement can be accommodated into the current systems. Currently, national laws are yet to fully extend their horizon to advancements such as human augmentation, biotechnology, software implemented invention, etc.

The international patent system has not only created a uniform and facile system for international patent application, but, it has aided in disseminating the need for protection of intellectual property. Further, it has set an excellent example when it comes to representation of international cooperation among various countries across the globe and the governmental organisations involved at a national level.

With regard to the dynamic between developed nations and developing to third world nations, due to the poor financial conditions of the latter technological growth is stunted, thereby making technology transfer the need of the hour.

Lastly, the patent systems need to be a little more flexible in nature in order to accommodate technological advancement and new innovations. Science is an ever-expanding field and this coupled with human intelligence and skill guarantees innovations which are way beyond the scope of such patent systems. In case of inadequacy of such systems, there could be an impediment in the growth of science thereby depriving the world of game-changing technology and innovations. In order to avoid this, the patent systems must be accommodative and adaptive to such technologies and innovations for the overall betterment of society.

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VI. Bibliography

Books

1. National Research Council, Global Dimensions of Intellectual Property Rights in Science and Technology, Washington, DC: The National Academies Press (1993).

Research Articles

1. Thomas C. Creel & Drew M. Wintringham, Patent Systems and Their Role in the Technological Advance of Developing Nations, 10 Rutgers COMPUTER & TECH. L.J. 255 (1984).

2. Joseph A. Greenwald, Technological Development and International Patent Problems, 33 J. PAT. OFF. Soc'y 5 (1951).

3. Elina Mangassarian, Technological Trends and the Changing Face of International Intellectual Property Law, 11 INT'l LEGAL Persp. 125 (1999).

4. Justine Pila, Bound futures: Patent Law and Modern Biotechnology, vol. 9.2, B. U. J. SCI. & TECH. L., (2003).

5. Dominique Guellec & Maria Pluvia Zunigia, The Role of Patent in Technology Markets: Issues Pertaining to Data Collection and Analysis, vol. 12.6 , First Monday (2007).

6. Rebecca S. Eisenberg, Patents and the Progress of Science: Exclusive Rights and Experimental Use, vol. 56, no. 3 ,The University of Chicago Law Review (1989).

7. C. Niranjan Rao, Recent Development in International Patent System, vol. 24, no. 51/52, Economic and Political Weekly (1989).

8. Meghana Banerjee & Yajnaseni Roy, Patentability of Incremental Innovation Vis-A-Vis 3(d) of the Indian Patents Act: Striking a Balance, vol 2.4, NUJS L. Rev. 608 (2009).

9. William Aldous et al. (eds.), Terrell On The Law Of Patents, Sweet & Maxwell, London (1982).

10. Jay Erstling & Isabelle Boutillon, The Patent Cooperation Treaty: At the Center of the International Patent System, 32 WM. MITCHELL L. REV. 1583 (2006).

11. Ania Jedrusik and Phil Wadsworth, Patent Protection for Software-Implemented Inventions, WIPO Magazine, published in February 2017.

12. LIO Xin and YU Xiang, Potential Challenges of 3D Printing Technology on Patent Enforcement and Considerations for Countermeasures in China, Journal of Intellectual Property Rights, Vol. 20, pp. 155-163, May 2015.

13. Stephen P. Ladas, Existing Uniformity of Industrial Property Laws and Revised Patent of Introduction: Means for Transfer of Technical Information to Less Industrialized Countries, 12 Idea: The Patent Trademark & Copyright J. Res. & Educ. 163, 163 (1968).

Online Articles:

1. William Weston Fisher, Patent, Encyclopaedia Britannica, 27 May 2019 available at https://www.britannica.com/topic/patent

2. The Sienna Project, What is Human Enhancement published on 31/03/2021 available at https://www.sienna-project.eu/enhancement/facts/

3. Copeland B., Artificial intelligence: Definition, examples, and applications, Encyclopedia Britannica (2019).

Case Laws

1. Diamond v. Chakrabarty, 447 U.S. 303 (1980).

2. Re Beauregard, 53 F.3d 1583 (Fed. Cir. 1995).

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