IPR Enforcement and Impact on BRIC Economies

With the TRIPS Agreement coming into force inAccording to the conclusion of this report,
1995, BRIC countries have undertaken significantincremental innovations" involving new forms, analogs,
reforms in their intellectual property systems. Aetc with significantly better safety and efficacy
relatively new analytical definition of the industrialstandards shall be encouraged.
components of the economy is 'Creative industries', inChinese social environment for the protection of
which creativity being an input and intellectualintellectual property right is complex. The locally
property is the output. Globally, mapping exercisesproduced generics and copy products dominate the
have concurred that the creative industries areChinese drug market. It is estimated that about 97
indeed 'economically significant' and legitimatelypercent of the drugs produced by local companies
comparable to other high profile sectors in terms ofare generics or counterfeits in China.
their contribution to income, employment and trade.The component available in all the BRIC compulsory
Concept of IPR in BRIClicensing statutes is the provision for government use
Brazil enacted its first intellectual property law in 1887.in times of national emergency. Commercial working
Brazil meets International Standards of Intellectualof patent is mandatory in India, Brazil and Russia. The
Property Protection. Brazil is a signatory of severalfailure to manufacture a patented article locally may
conventions, treaties, and agreements that definelead to the imposition of a license. According to Indian
basic, internationally-accepted standards of intellectualPatent Act importation does not amount to working
property protection including, among others, theof a patent. Perhaps the most significant compulsory
Patent Cooperation Treaty (PCT). Brazil is also alicense use by BRIC countries will come not from
member of Trade-Related Aspects of Intellectualsupplying the home market, but rather from
Property Rights (TRIPS). The new Industrial Propertyexporting pharmaceuticals to developing or
Law came into force in May of 1996. This lawleast-developed countries that have taken out
brought Brazil's patent and trademark regime up tolicenses. As explained above, India, China and Brazil
par with the international standards specified ineach have significant pharmaceutical manufacturing
TRIPS. Intellectual Property protection in Brazilsectors and are accomplished at producing generic
includes Copyright Law, Software Law and also somemedications and all of them are the members of
secondary laws.TRIP. Natco had filed application for compulsory
In Russia the concept of IPR was understood aslicenses for export of generic anti-cancer drugs
mostly patents during the times of the former SovietSunitinib and Erlotinib, both patented in India to Nepal
Union. The owner of the Patents as well as allunder section 92A of the Indian patent law.
innovations was always the state. The concept ofHowever, Natco subsequently requested Controller
IPR has already been drastically changed in Russiaof Patents to withdraw its applications for
and now IPR is seen in consisting of Patents,compulsory licenses.
Trademarks, utility modes, designs, domain namesDespite the similarities in compulsory licensing
and copyrights. After 10 years of Russia'sprovisions, there is a significant divergence in how
independence, the country has started to come intothose flexibilities have been historically utilized in the
compliance with International requirements forBRICs. The differences serve as an outline of relative
intellectual property rights protection. Today alsointellectual property development, and may provide a
much work is needed to be done to bring Russia upmetric for future evaluation. More importantly, it is
to International standard.possible that one path will provide the paradigm for
Indian Intellectual Property Laws keep pace with thethe other BRICs seeking a balance between rights
technological developments & Intellectualand access.
Property Laws of other countries. India has differentEconomic Significance of IPR on BRIC economies
positions with respect to intellectual property right inWith the BRICs strengthening their IPR systems
prior to the member of TRIPS and after theduring the past decade they have experienced
signatory of TRIPS agreement. Patent, Copyright,increases in real flows of imports and increases in the
Trademark and Design were only existed as branchreal stock of inward FDI (Foreign Direct Investment).
of IPR prior to TRIPS agreement. However, atThe authorities in BRICs have exhibited stronger IPR
present Patents (Amendment) Act 2005, TradeMarkspolicies, because of the recognition that infringement
Act 1999, Copyright Act 1999, Design Act 2000,activities impose a cost in terms of foregone tax
Trade secrets, Layout Design of Integrated circuitsrevenues and job creation, with adverse affect on
2000, Geographical Indications 1999 and Plant Varietyinward technology transfer as well as domestic
2001 related to IPR are enforced in India. India signedinnovation.
the TRIPS agreement in 1995, joined Paris conventionBetween 2000 and 2005, the BRIC countries made a
in 1998, Budapest Treaty in 2001, Universalcontribution of 28 percent of the global growth in
convention for Copyright (UCC) in 1952, Washingtondollar terms and 55 percent in purchasing power
Convention for Integrated Circuit in 1989, andparity terms. The intra- BRICs trade also reported to
convention in Bio-diversity (CBD) in 1994. India isaccelerate to 8 percent from 5 percent in 2000. In
signatory to Berne Convention and IndianBRIC countries technology transfer via trade and FDI
Government has already approved Madrid Protocol.has been an important factor into developing
China has had a history of 25 years in the filed oftechnological capabilities. There have been countless
Intellectual property rights protection. China's currentsigns of developing trade relationships, including the
legal IPR framework began in the 1980s, however, insharp spurt in Brazilian trade with China, Chinese
that short time, China has made impressive strides ininvestment commitments in Brazil and the exponential
protecting and enforcing IPR. China became thegrowth in trade between China and India.
member of WIPO in June 1980. The patent law ofIPR alone does not determine technological success
the People's Republic of China (PRC) was adopted inor even increased access to technology, other
1984. In 1993 the law of the PRC against unfaircomplimentary factors that specifically affect
competition was enacted and the copyright law wasinnovation and technology diffusion such as quality of
enforced in 1990.knowledge institutions, financial system, availability of
Enforcement of IP Rightstrained human capital, and networks for research
The originate and history of IPR in BRIC countries ascollaboration or interaction are the important factors
explained above indicates the protection andwhich BRICs have to facilitate for the technological
enforcement of intellectual property rights in thesuccess.
BRIC countries has also been introduced long back ,Software Patents: A unique field of patenting
and the journey is clearly far from over.There is intense debate over the extent to which
In spite of having diverse histories, the BRICsoftware patents should be granted. Different
economies are receiving roughly similar treatmentcountries and regional offices have different
from the wealthiest nations. Copyright and trademarkstandards for granting software patents. Section 3(k)
piracy have always been chosen as a topic for theof the Indian patents act prohibits the grant of the
assessing the future of BRIC intellectual propertypatent an invention that is directed to software per
regimes. However, other areas of intellectualse. Indian Patent Office has now introduced Draft
property protection have broader significance toIndian Patent Manual 2008. As per section 4.11.6 of
most industries and play a vital role in the economicDraft Indian Patent Manual 2008, the method claim
development of the industry as well as the nation. Inshould clearly define the steps involved in carrying out
particular, the impact of patents on innovation andthe invention. It should have a technical character. In
economic performance is so complex that a wellother words, it should solve a technical problem. The
organized patent system is crucial to ensureclaim orienting towards a "process/method" should
maximum benefit for a country's firms and its overallcontain a hardware or machine limitation. Technical
economy.applicability of the software claimed as a process or
Despite divergent pasts, the BRICs are generally onmethod claim, is required to be defined in relation
the same page today when it comes to thewith the particular hardware components. Brazil
protections afforded pharmaceuticals. The revisedprovides special protection to software by copyright
law in Brazil now complies with TRIPS, at least inand software laws which came to effect on 19th
regard to subject-matter protection. Brazil instituted aJune, 1998 and Feb 1998 respectively. A US federal
formal system for the approval of genericcourt Judgment on disallowing business method
pharmaceuticals. After Russia instituted modernpatenting, may have a direct impact on the ongoing
patent property rights with individual ownership,debate over amendments to the Indian patents
Russia currently protects pharmaceutical patents. Themanual. It has been studied that Business method
previous Indian Patents Act (1970) recognizedpatents are seven times more likely to be litigated as
patents on pharmaceutical 'processes', but not oncompared to other patent.
'products', allowing domestic pharmaceuticalIn Brazil infringement of copyright in software can
companies to produce cheap copies of patentedgive rise to criminal penalties. After the Berne
drugs made by foreign companies using alternativeConvention, computer software was treated as a
production methods. India's introduction of productkind of literary work under the Copyright Law in
patents in 2005 heralded innovation and rapidChina. Software is still barred from patenting in Russia.
development of that nation's pharmaceutical sectorConclusion
and delivery of new medicines. The MashelkarBRICs have all found their own way in preserving at
Committee revised report was submitted in Marchleast some legal sovereignty in the intellectual
2009 concluded that every effort shall be made toproperty arena. Although the BRICs have so far
provide drugs at affordable prices to people of India.grown more than envisaged, yet all is not
The report also stated that it would not be TRIPSsatisfactory as far as the economies of BRICs are
compliant to limit granting of patents forconcerned. Current success is obviously no guarantee
pharmaceutical substance to NCE (New Chemicalof future performance. More progress is required if
Entities) only, and exclude an entire class ofthey are to continue to deliver the best possible
inventions i.e incremental pharmaceutical inventions.outcomes over a longer period of time.