What are the difference between US and EP Patent system?

[Senthilbrain]

What are the difference between US and EP Patent system?

 

[cyjeff]

Dunno... language?

This is a US forum. We really don't have any EP experts... at least that I have seen.

 

[divgradcurl]

What are the difference between US and EP Patent system?

There are many differences. Two of the key differences, with respect to actually obtaining a patent, is that the U.S. has a "first to invent" system while the rest of the world (and the EU) go with "first to file," and the U.S. has a one-year "grace period" in which to file for a patent, whereas the EU has a requirement for absolute novelty. Might want to look here: Differences between US and European patents (in Patents @ iusmentis.com)

Once a patent is granted, the systems are different as well. In the U.S., an issued patent is presumed valid; in many countries, a patent is not presumed valid, and must be proven to be valid in litigation.