In the context of a globalised economy, companies often file
patents in multiple countries and areas to protect their
technological innovations. To reduce costs, companies often submit
identical application documents across several countries and areas.
However, due to differences in patent laws, if these documents are
not appropriately adjusted according to local regulations and
practices,the patent applicationmay be rejected due to patent
eligibility — especially for inventions involving computer
technology, algorithms, and AI.
This article analyses the differences between China and the US
in the assessment of patentable subject matter andpatent
eligibility through an exploration of key concepts and a case
study. It aims to provide practical guidance for practitioners,
helping them to tailor application documents to meet legal
standards in different jurisdictions and reduce the likelihood of
rejection.
