Executive Summary: This article compares U.S. 37 C.F.R. § 1.132 declaration practice with the closest Korean analogue: a KIPO written argument supported by experimental results, comparative data, expert explanation, or other technical evidence. It explains that both systems use evidence to overcome examiner rejections when attorney argument alone is insufficient, especially in obviousness or inventive-step disputes involving unexpected or advantageous technical effects. But

Executive Summary: This article examines how the meaning of “inventor” differs across the United States, Europe, South Korea, China, and Japan, focusing on whether inventorship is determined by the inventions claimed or by everything described in the application. It distinguishes the legally relevant object of the inquiry from the evidence used to identify its creators: claims may define the invention, while the specification, drawings, prior art, and development record revea

Executive Summary: This article compares how prosecution history can limit patent claim scope in the United States, the EPO, Korea, Japan, and China. In the United States, prosecution history operates through several related doctrines: ordinary claim construction, prosecution disclaimer, amendment-based prosecution history estoppel under Festo, and argument-based estoppel where applicant remarks clearly surrender subject matter. The EPO stands apart because EPC proceedings ge

Executive Summary: Bayh–Dole is best understood not as an automatic university-ownership rule, but as a conditional government–contractor bargain that permits a contractor to retain title to qualifying federally funded inventions while preserving disclosure and patenting duties, utilization reporting, a paid-up government license, domestic-manufacturing safeguards, nonprofit-specific restrictions, and discretionary march-in authority tied to practical application. A comparati

Executive Summary: The article explains why Korean software and AI patent applications that appear eligible under Korean law may still face significant obstacles under U.S. patent-eligibility doctrine. Korean law focuses on whether the claimed invention is a “technical idea utilizing laws of nature” and, for software-related inventions, whether software-based information processing is concretely realized using hardware. U.S. law, by contrast, asks whether the claim falls with