Living Things As Compositions of Matter
In Diamond v. Chakrabarty, the United States Supreme Court held that a genetically-altered living microorganism was patent-eligible subject matter. The Chakrabarty Court said that "we must determine whether respondent's micro-organism constitutes a 'manufacture' or 'composition of matter' within the meaning of the statute. The Court's answer to its question was yes----"respondent's micro-organism plainly qualifies as patentable subject matter." But the Court never said which one it was.
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