Intellectual property in common law and civil law / edited by Toshiko Takenaka, University of Washington School of Law, USA.

Includes bibliographical references and index.

Towards a history of patent law / Brad Sherman -- Ordre public and morality issues in patent eligibility / Joseph Strauss -- First-inventor-to-file under the America Invents Act : a view of first-to-file lawyer and a view of first-to-invent lawyer / Toshiko Takenaka with Martin J. Adelman -- The inventive step and cooperative harmonization / Amy L. Landers -- Equitable doctrines in international patent laws / Jan Krauss -- Tradition and change : the past and future of authors' moral rights / Mira T. Sundara Rajan -- Japan's copyright law revisions, disruptive innovation and user-generated content / Salil Mehra -- The dragon and the white whale : three steps test and fair use / Frédéric Pollaud-Dulian -- Fair use : a tale of two cities / Sang Jo Jong.

Passing off and unfair competition regimes compared / Mary LaFrance -- Trade dress / Signe H. Naeve -- A comparative analysis of the protection of geographical indications in the European Union and the United States under sui generis and trademark systems / Gail E. Evans -- Extraterritorial enforcement / Marketa Trimble -- Injunctive relief in patent cases in the US, Germany and Japan : recent developments and outlook / Christoph Rademacher -- What the treatment of covenants not to compete teaches about intellectual property and competition norms / Shubha Ghosh -- Employee invention system : comparative law perspective / Toshiko Takenaka and Yves Reboul -- Exhaustion of intellectual property rights in the European Union / Theo Bodewig -- The patent laws of old / Mario Franzosi.

Despite increasing worldwide harmonization of intellectual property, driven by US patent reform and various EU Directives, the common law and civil law traditions still exert powerful and divergent influences on certain features of national IP systems. Drawing together the views and experiences of scholars and lawyers from the United States, Europe and Asia, this book examines how different characteristics embedded in national IP systems stem from differences in the fundamental legal principles of the two traditions.