2023
DOI: 10.1177/1023263x231206007
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Patent law in comparative context: Differences and similarities of patent law in the European Union, the United States and China

Päivi Hutukka

Abstract: This study presents the main features of patent law in the European Union, the United States and China, with a special focus on patentability. Each patent regime is reviewed in its historical context, exploring the stages leading to the given jurisdiction's contemporary patent law. After mapping the differences and similarities of patent law in the EU, the US and China, possible reasons for the detected divergence and convergence will be explored. This study reveals that the differences in codified patent law … Show more

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