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May 28, 2024

Stewart Cameron – Reflections From The US – US Vs European Patent System


#USPatent #EuropeanPatent Having just got back from a week in the US (at INTA in Atlanta then presenting at PIPLA in Philadelphia), I’ve spoken with many US attorney colleagues, and one question I have been asked is: “What do you think is better – the US or the European patent system?”.  

I think both have evolved very differently, with the main difference of course being that the US, as a national entity, has long-established systems to befit its national status, whereas the European system, involving multiple national entities, has had to find a way of finding harmony between those, which has often been tricky, not least in relation to the recent creation of the Unified Patent Court (UPC) as a European litigation forum. 

As regards Europe, I find that, because all the European partners have had to really discuss and negotiate on what the system looks like and how that evolves, the system created has taken on board some of the best ideas and the European system is the better for it, but goodness me, it has always taken a long time to find agreement!  

The US system is quite streamlined, and the different education and training of those involved vs the European system, means that they often have different perspectives to myself and my European colleagues – which I find is a good thing when we’re working together on global portfolios for our clients.  

Ultimately, I believe what matters most is that last point of how we engage together to produce the best results for our clients, ideally getting both US and European patent attorneys involved at the drafting stage, to strengthen the patent applications for any future challenge in any of the various global opposition and litigation forums (we assist a number of US-based clients with drafting claims from a European perspective). 

Always keen to hear other opinions on the best / worst parts of the two systems, and indeed how we can work better together! Please contact me via my email address below.

Stewart Cameron, Director

European & UK Patent Attorney, Unified Patent Court Representative

E. / T. +44 (0)208 390 377

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