A Comparative Study of U.S. and Japanese Patent Systems

Abstract

In an era of global competition, adequate protection of intellectual property in Triad regions of the world, particularly in Japan, has become increasingly important. This study focuses on the differences and similarities in patent practices between Japan and the United States. British and German patent practices are also examined to offer a balanced comparison. Findings indicate that the Japanese patent practices seem to discriminate against foreign applicants with longer pendency periods than for domestic applicants, while the U.S., German, and British patent practices appear to discriminate against foreign applicants with lower patent grant ratios than for domestic applicants.