Abstract
A comparison of patent law relating to business method inventions in the USA, before the European Patent Office, and in the UK. Broadly speaking, the interpretation of the US, UK, and European patent law concerning what can and cannot be patented appears to have been largely finalized. However, as new cases are heard the status quo is often disturbed, and this can make the application process difficult and expensive for applicants. The UK and European positions differ, despite guidelines indicating that as far as possible, the positions should be the same. In the USA also, although the approach is very different to Europe and the UK, a debate seems still to be raging as to the limits of the subject matter for which patents should be granted. The article will be helpful for anyone who wishes to quickly understand the present approach to business method inventions in these three jurisdictions.
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