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the fact that the Japanese system is "adopted" from Germany, whereas the U.S. system is rooted in the long history of common law.

One observer from the Arab Society for the Protection of Industrial Property noted that harmonization among the United States, Japan, and the EC seemed the most feasible, not because there are fewer disagreements or differences in their IPR systems, but because they collectively possess nearly all of the technological capacity in the world and have a natural, common interest in establishing strong protection for their assets. By the same logic, he argued, it should not be surprising that there is little incentive for the rest of the world to embrace this level of protection, since the majority of the world operates under completely different circumstances.

Many participants at the conference thought that the different technological and economic circumstances among countries must at least be acknowledged by the industrialized world as it pushes for a uniform system. To the lesser developed countries (LDCs), granting individuals or companies strong property rights to new varieties of grain seems counterintuitive when hunger is a basic problem for most of them. On the other hand, as LDCs have watched foreign pharmaceutical companies turn native germ plasm into valuable new medications beyond the purchasing power of their citizens, they have sought to gain recognition for the concept of "property rights" in local gene pools by the country of origin. As one audience member asked, "Can we distinguish between intellectual property rights for a razor blade and for a rice strain simply keeping in mind that food crops are closely linked to basic human rights, which are perhaps not an intellectual property right but are still a right?" The LDCs have difficulty taking the leap of faith needed to accept the logic that by extending private rights, temporary monopolies, and monetary incentives to individuals, the public ultimately will benefit.

The challenge of addressing LDC concerns in an international IPR dialogue prompted a discussion on the suitability of the GATT negotiations on Trade Related Aspects of Intellectual Property Rights (TRIPS) to serve as the forum in which to move toward uniformity. Given the origins of GATT as a mechanism for trade enhancement among industrialized countries, and the fact that the industrialized countries have controlled the agenda and rulemaking process of GATT ever since its establishment, it may not be a suitable forum for a North-South discussion. On the other hand, it was contended that because these multilateral talks address trade issues in a variety of sectors, the GATT presents an opportunity to make cross-sectoral agreements to the economic benefit of all parties.

The success of GATT is dependent, however, on agreement across all sectors. Given the difficulty of justifying to the LDCs on an empirical basis the benefits of specifics of the Dunkel draft in the TRIPS negotiation, the industrialized countries may have to be willing to make trade-offs in terms



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