A Case Comment on Diamond V Diehr, (1981) 450 US 175

The patent application was rejected by the Patenta strong protection even if its period is short. That
and Trademark Office Board of Appeals rejecting themeans, they would like get a protection of the
claim for curing synthetic The Court of Customs andtechnical application of the software itself, which
Patent Appeals reversed the order. The subjectconstitutes a functional aspect, an ingredient to get
process constituted patentable subject matter that inpatent protection. It seems clear that software
several of its steps it included use of a mathematicalpatents are actually preventing the adoption of new
formula and a programmed digital computer, astechnology rather than encouraging innovation. In
process involved transformation of uncured syntheticIndia software patents are impossible. The argument
rubber into a different state or thing and solved anadvanced against patenting in India is that copyright
industry problem of "undercure" and "overcure". Thelaw can adequately safeguard the interests of
claim satisfies one of the tests to proveauthors and as such no patenting would be
non-obviousness which was enumerated in the casenecessary and patenting would hinder innovation and
of Biogen v. Medeva, in which a problem in rubberdevelopment of new technology, which can act as a
industry of overcuring or undercuring was resolved,launch pad to propel the economy.
by ensuring the time of curing the rubber with theThe recent developments regarding the grant of
help of the new device included in several of itssoftware patenting in USA and in other parts of the
steps use of a mathematical formula and aworld is that it has become a serious threat to the
programmed digital computer. The computerOpen Source Licensing. There is tremendous
programmes can be categorised as a kind ofanimosity in the free software community towards
algorithms or mathematical formula. In United Statessoftware patents. Today, even companies such as
of America mathematical programmes, algorithms andIBM, Sun, Texas Instruments, and CISCO have joined
scientific truths are outside the purview of patentthe growing Free and Open Source Software (FOSS)
protection. But the court held that the merecommunity opposing software patents. Most of
presence of a software element did not make anthese companies have publicly stated that they are
otherwise patent-eligible machine or processfiling patents only for defensive purposes. Indian law
un-patentable. The United States Supreme Courtalso bars software patents. With regards to
came with a remarkable judgment by giving a newproprietary versus FOSS, India needs to analyse and
interpretation for the protection of software. We candefine what should be its trajectory. There is enough
say that, it was the beginning of software patentinggrounds to believe that if Indian companies want to
in United States. It distinguishes the computermove from services model to a product model,
programmes as computer programmes per se andsoftware patents and proprietary software will not
computer programmes which are used for thebe the route to take instead, India should promote
industrial application of a device. The significance ofFOSS, as Brazil and China are doing. Much of this has
practical application of software in the business andbeen caused by free software or open source
technology was recognised and appreciated at theprojects shutting down when the holders of patents
infancy of software industry itself.covering aspects of a project demanded license fees
In India by The Patents Act 1970 as Amended bythat the project could not or was not willing to pay
(Amendment) Act, 2002 radically changed theor offered licenses under terms which the project
definition of "invention" and also excluded "awas unwilling to accept, or could not accept because
mathematical method or a business method or ait conflicted with the free software license in use.
computer programme per se or algorithms" fromThe meaning of patents itself is the disclosure of
patentability. The Indian legislature appears to haveinvention by the inventor to the society or state and
tacitly approved the formulation in this case bystate will grant a temporary monopoly to the
importing the wording. It was generally understoodinventor. Grant of patent is an incentive to innovation.
that a product embedded with a computerSo in my view, since software creation comes within
programme producing a 'technical effect' and havingthe definition of "invention", it is proper to give
an inventive step is patentable. In India computerprotection of software under patents rather than by
programmes per se are protected under Thegiving protection under copyright law. Software is not
Copyright Act, 1957 as a literary work. It protectsmerely a language containing source code and object
only the language of the computer programme i.e.code. It has a function and it is an application which
object code and source code, but not its technicalsatisfies the criteria of "inventive step" for patents
application. The software manufacturing companiesprotection. In my opinion, equipping software with
will get a long term protection under copyright law.copyright protection in fact degrades the significance
They do not want a long term protection, but wantof soft ware inventors.