Diamond v. Chakrabarty - Case Summary

Legal Case Summary

Facts

Ananda Mohan Chakrabarty, a Genetic Engineer at General Electric, had genetically modified a type of Pseudomonas bacteria to consume oil spills (Epstein, 2006). To protect his work, Chakrabarty applied for a patent. The patent examiner denied his application stating that living things were not patentable under the 1930 Plant Patent Act.

Chakrabarty appealed to the Patent Office Board of Appeals which upheld the rejection. He then appealed to the Customs Court, which reversed the decision and granted the patent. The US Commissioner of Patents and Trademarks, Sidney Diamond, appealed to the Supreme Court.

Issues

The main issue of the case was whether a live, human-made microorganism is patentable subject matter under the US Patent Act (35 U.S.C. § 101). The debate centered on the interpretation of the law's phrase "any new and useful... manufacture, or composition of matter."

Analysis

The decision in Diamond v. Chakrabarty drastically expanded the scope of what could be considered patentable (Dutfield, 2009). The ruling established the legal framework for the patenting of life forms and has had profound impacts on biotechnology and genetic engineering. In the broader sense, its implications extend to the biotech industry, pharmaceutical companies and agriculture.

Decision

The Supreme Court ruled 5-4 in favor of Chakrabarty (Diamond v. Chakrabarty, 447 U.S. 303). The Court held that while natural phenomena, laws of nature and abstract ideas are not patentable, human-made organisms are not natural and thus are subject to patents.

References

• Epstein, R. A. (2006). The Constitutional Protection of Trade Secrets and Patents Under the Biotechnology Directive. European Journal of Law and Economics, 21(3), 253-283.
• Dutfield, G. (2009). The Public and Private Domains: Patent Rights and Public Health. Chicago-Kent Journal of Intellectual Property, 7(1), 1-17.

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Journalist Brief

Diamond v. Chakrabarty was a monumental legal case in the US where the Supreme Court ruled that living, genetically modified organisms could be patented. This case was centered on a genetically engineered bacteria capable of breaking down crude oil, created by Ananda Chakrabarty. The decision set an important precedent in the biotech industry, impacting genetic engineering, pharmaceuticals and agriculture by widening the scope of what can be considered patentable.

FAQs

What was the significance of Diamond v. Chakrabarty?

Answer: The case is significant because it expanded the scope of what could be patentable, to include genetically modified organisms. It also set an important precedent in the biotech industry.

What did the Supreme Court rule in Diamond v. Chakrabarty?

Answer: The Supreme Court ruled that living, genetically modified organisms could be patented, so long as they are the result of human ingenuity and not naturally occurring.

Who was the plaintiff and defendant in Diamond v. Chakrabarty?

Answer: The plaintiff was Sidney Diamond, the US Commissioner of Patents and Trademarks, and the defendant was Ananda Chakrabarty, a genetic engineer at General Electric.