Diamond v. Chakrabarty

In Diamond v. Chakrabarty, 447 U.S. 303 (1980), the Court addressed the question whether a man-made, living microorganism is a patentable manufacture or composition of matter within the meaning of 101. 447 U.S. at 305, 307. The microorganisms were bacteria genetically engineered with four naturally occurring DNA plasmids, each of which enabled the breakdown of a different component of crude oil. Id. at 305, 305 n.1. The bacteria, as a result, could break down multiple components of crude oil, a trait possessed by no single naturally occurring bacterium and of significant use in more efficiently treating oil spills. Id. at 305, 305 n.2. The Court held that the bacteria qualified as patentable subject matter because the claim is not to a hitherto unknown natural phenomenon, but to a nonnaturally occurring manufacture or composition of matter-a product of human ingenuity having a distinctive name, character and use. Id. at 309-10. In Diamond v. Chakrabarty, 447 U.S. 303 , 309 (1980), scientists added four plasmids to a bacterium, which enabled it to break down various components of crude oil. 447 U.S., at 305, and n. 1. The Court held that the modified bacterium was patentable. It explained that the patent claim was not to a hitherto unknown natural phenomenon, but to a nonnaturally occurring manufacture or composition of matter-a product of human ingenuity having a distinctive name, character and use. Id., at 309-310.