As its name suggests, a business method patent grants to its holder
exclusive rights to a particular way of doing business. Until recently,
it was widely assumed that business methods were not patentable.
As a result, firms enjoyed only limited intellectual property protection
against imitation of their strategies by competitors. Some innovations
could be kept secret, and innovators could prevent competitors from learning
of those innovations by "improper means." However, most innovations
could not practicably be concealed, and competitors were thus free to mimic
them. The 1998 decision by the Court of Appeals for the Federal Circuit
Street Bank & Trust Co. v. Signature Financial Group, Inc., 149 F.3d
1368 (1998) altered this situation dramatically.
That decision upheld a patent on a software program that was used to make
mutual-fund asset allocation calculations. In the wake of that decision,
companies have been seeking -- and obtaining -- business method patents
at a furious pace. The U.S.
Patent and Trademark Office (USPTO) reports that, in 1998, 1300 patent
applications pertained to business methods, and 420 such patents were issued.
In 2000, 7500 applications for business method patents were filed, and
1000 such patents were issued. Because a large
percentage of those patents involve methods of doing business online, they
merit our attention.
The frenzy over business method patents is by no means confined to the
United States. The European and Japanese Patent Offices, which together
with the U.S. cover about 84%
of the patents worldwide, similarly recognize business method patents (although
under stricter patentability standards.) Many other countries are
in the process of forming their policy toward this new category of patents.
Meanwhile, considerable controversy continues to swirl around business
methods patents in the United States, and Congress is currently considering
legislation that would limit their availability. In sum, business
method patents are here to stay, but their availability or character may
change in the near future.
Introduction | Readings | Examples
| Discussion Topics | References
Note: The following materials assume an understanding of the main
features of patent law. If you are unfamiliar with this field, you
might find helpful the attached brief
summary or the more extensive outline provided by Michael
Defining and Enforcing Business Method Patents
Business method patents (hereinafter, BMPs), like all other patents,
are defined by their claims
-- the language, typically resulting from a tug of war between the patent
applicant and the patent examiner, that identifies the products or processes
to which the patentee can lay exclusive claim. The difficult task
of interpreting those claims is assigned to a judge -- usually in the context
of a so-called "Markman" hearing (named after the Supreme Court's decision
v. Westview Instruments, 517 U.S. 370 ). In the past few years,
federal courts, when engaged in Markman hearings, have often interpreted
BMPs fairly broadly. Here are two examples:
E-Data had a patent on remote imprinting of information into material objects
(such as songs into records) at points of sale, arguably a significant
improvement on the traditional method of centrally producing such objects
with the information, and shipping them to points of sale. This new way
of doing business saved both the cost of the shipping mechanism, and the
costs of over and under production that stemmed from the need to estimate
demand at points of sale initially and produce accordingly. E-Data sued
for infringement 18 defendants, who distributed information by way of download
via the Internet, rather than sale of content on floppy disks or CD-ROMs.
Judge Jones of the Southern District of New York interpreted E-Data's claims
narrowly, as to exclude most forms of electronic commerce and then dismissed
the case without making any findings of fact. On appeal, the U.S.
Court of Appeals for the Federal Circuit (court of last resort for patent
cases with the exception of the U.S. Supreme Court) determined
that the district court had adopted an excessively narrow interpretation
of the patentees' claims. The Federal Circuit therefore remanded
the case for further proceedings.
The dispute between Amazon.com and Barnesandnoble.com -- the most famous
of the BMP cases -- also involved, among other things, a Markman hearing.
Amazon.com was granted a patent
for a "1-click" e-commerce ordering system , which enabled a repeat
customer to purchase an item with a single click of his or her mouse (i.e.,
without having to provide his or her address, shipping preferences, credit-card
number, etc.). Relying on this patent, Amazon.com sought to prevent
its competitor, Barnesandnoble.com, from employing a similar system.
The district court found that Amazon had shown "a likelihood of infringement"
by Barnesandnoble.com and consequently issued a preliminary injunction.
The Federal Circuit approved the District Court's generous interpretation
of Amazon's patent. However, (for reasons considered in the next section),
appellate court found that Barnes and Noble had raised sufficient questions
concerning the validity of the patent that the issuance of the preliminary
injunction was improper.
Controversy over Business Method Patents
Can I patent this?
§101 defines patentable subject-matter as to include any new and
useful process, machine, manufacture or composition of matter. The U.S.
Supreme Court has construed this provision broadly -- specifically, as
establishing the principle that "anything under the sun that is made by
man" is potentially patentable (see: Diamond
v. Chakrabarty). Laws of nature, natural phenomena, and abstract
ideas, however, are unpatentable (Diehr)
-- the first two because they are not man-made, and the third because abstract
ideas, by themselves, are not useful.
Computer-implemented business methods were traditionally considered
to be outside the scope of patentable subject-matter for two independent
reasons. First, software programs of all sorts were for many years
consided unpatentable, because they were thought to be merely elaborate
mathematical algorithms, a sub-category of abstract ideas. The State
Street Bank decision followed a recent line of cases (e.g., In
re Alappat , 33 F.3d 1526 (Fed. Cir. 1994)) which rejected this traditional
view and instead took the position that, when an algorithm is reduced to
a practical application and produces a useful, concrete and tangible result,
it can be patented. But State Street Bank's principal innovation
consisted in laying to rest what it described as the 'ill-conceived' previously-existing
'business method exception to patentability.' Applications for patents
on business methods, the Federal Circuit held, were not different from
applications for patents on other processes. The United States Supreme
Court refused to review the ruling, and the following year, in AT&T
Corp. v. Excel Communications, the Federal Circuit reiterated its position.
Where the law in the United States now stands, computer-implemented ways
of doing business are certainly patentable.
Isn't it Obvious?
Much of the controversy over BMPs centers around the USPTO’s procedures
for prosecuting these applications. It is often alleged that the
Patent Office is issuing patents on old methods of doing business that
are now being implemented on the Internet. Critics complain that
Internet-based business methods are "obvious" -- and thus, pursuant to
35 U.S.C. §103,
ought not receive patents. An “obvious” invention is one whose subject
matter would have been apparent to a person having “ordinary skill in the
art” at the time the invention was made. See
v. John Deere , 383 U.S. 1 (1966). An examiner can infer
the obviousness of a BMP from established business practices, or from the
automation of known practices normally done manually. Once the examiner
makes a prima facie case of obviousness, the applicant has the opportunity
to rebut it in any of several
established ways. The issuance of a patent by no means ends the
inquiry into the obviousness of an invention; typically the defendant in
any subsequent patent infringement suit will raise the issue anew in an
effort to persuade the court to invalidate the patent. A successful
argument of this sort enabled Barnes & Noble, in the case described
above, to persuade the
Federal Circuit to overturn a preliminary injunction that had been
granted to Amazon.com to protect its "one-click" checkout system.
In March of this year, that case was finally settled.
Haven't we seen it somewhere before?
Another statutory requirement for patentability, embodied in
U.S.C. §102 , is "novelty." Novelty means that the invention
must contain something not already reflected in the body of prior art.
Novelty is read together with statutory bars, which require the inventor
not to delay unduly in seeking patent protection.
The Search for Prior Art
To make a claim of invalidity based on either lack of novelty or obviousness,
the patent examiner must first identify relevant “prior art.” The
Patent Office has had a difficult time identifying prior art in business
method cases. Until recently, business methods were commonly kept
secret by innovators in order to give them competitive advantages.
Consequently, the PTO's traditional printed resources (such as patents,
journal articles, academic dissertations, company literature, etc.) are
not good sources of prior art for this type of patent application.
Additional difficulties arise from the fact that, whereas the patent office
examiners are highly skilled in some field of technology (e.g., electrical
and/or computer engineering), they are not required to have any background
in business. Therefore, the examiners may not necessarily recognize
or know where to look for established practices in different business environments.
The public, including business executives, can be an important resource
in locating and identifying business method prior art. In an ironic
twist to the business method patent controversy, a new website BountyQuest.com
has been launched. (A second ironic twist is that Amazon.com's Jeff
Bezos teamed up with Tim O'Reilly to launch this site.) This site
allows anyone to post a bounty (at least $10,000) for prior art that, once
revealed, would render invalid a particular business-method patent.
The public is invited to respond to these postings and collect the bounty.
Some of the earliest postings were on familiar patents such as Amazon.com’s
1-click patent ($10,000
bounty), SightSound’s digital download patent ($40,000
bounty), Priceline.com’s reverse
auction patent ($20,000
bounty), and even BountyQuest’s own business method ($14,159
bounty), whose application is pending. The founders of this website
hoped to encourage good patent applications, as well as to help those in
the industry invalidate the "bad" ones. At least eight individuals
have already received bounties for proffering prior art. Their names
and pictures appear in the
Hunter Hall of Fame.
Are Business Method Patents Fundamentally Different?
There is a close connection between BMPs and software patents,
since many of the business methods that are being patented are
implemented with software. Are these two types of innovation
really different from machines, methods of manufacture, and other
things on which the patent office has granted patents for hundreds
of years? In response to the uproar over Amazon.com's patents
and pending litigation, Jeff Bezos (of Amazon.com) has proposed
that business methods (and software) ought to be patented for
a shorter period of time. Bezos and Tim O'Reilly have been
adamant in their opposing
stances on this issue. Unfortunately, Bezos' suggestion
most likely would violate the World Trade Organization's (WTO's)
Trade-Related Aspects of Intellectual Property Rights (
TRIPs ) agreement, to which 144
nations , including the United States, are signatories.
33 of the agreement requires utility patent terms to be no
shorter than 20 years from the filing date.
What is the Role of the Legislature?
Not to be left out, Congress has turned its attention to BMPs.
In April 2001, Democratic representatives Howard Berman (CA) and Rick Boucher
(VA) introduced the Business
Method Patent Improvement Act of 2001, a slightly modified version
of a previous
bill they had proposed six months earlier. The Act's main goal is to ensure
the high quality of newly issued BMPs, and it offers several means to this
end. If passed, it would create an administrative opposition proceeding
that could be initiated by anyone within 9 months after a patent issues
- a faster and cheaper alternative to litigation. This proceeding would
be conducted before an administrative opposition judge, and result in a
determination that could be appealed in court. During the proceeding, the
patent holder would be given an opportunity to amend the patent claims
as long as the amendments only narrowed or maintained their scope.
Additionally, the Act would require publication of all BMPs 18 months after
filing, and would allow the public to submit relevant prior art to any
published application. The bill lowers the burden of proof for challenging
business method patents, requires an applicant to disclose her prior art
search, and last but not least, creates a rebuttable presumption that a
business method invention constituting a non-novel computer implementation
of a pre-existing invention is obvious, and thus, not patentable.
On April 4th 2001, a day after the new Act was introduced, the House Judiciary
Subcommittee on Courts, the Internet and Intellectual Property,
had convened an oversight hearing on BMPs. The two lawmakers defended
their view that standards for BMPs should be tightened.
Resisting the new legislation, acting director of the USPTO, Nicholas
Godici, stated that the PTO's BMP initiative (see below) is sufficient,
and Michael Kirk, executive director of the American Intellectual
Property Law Association (AIPLA), stated that the Act could be
incompatible with U.S. obligations under TRIPs. Rep. Howard
Coble (R-N.C.), chairman of the subcommittee, seemed to oppose
the proposed legislation.
Change at the USPTO
The USPTO has responded to the public's and industry’s concerns.
On March 29, 2000, it released an action plan to revamp the examination
procedures for this class of applications ("class 705"). Recently,
it also released a white
paper, which outlines its new examination procedures. The
AIPLA has also released a white
paper, recommending similar changes.
One goal of the USPTO is to obtain better information concerning relevant
prior art for each application. To that end, it is hiring and retaining
examiners who have significant business experience and expertise.
It is also updating its electronic databases to include non-patent literature
(NPL) that would be relevant to this class of patent applications.
The USPTO has additionally been working to establish partnerships with
industry associations and corporations to continually address new industry
concerns. The first business methods partnership
meeting was held on March 1, 2001. Approximately 90 participants
attended, and identified a number of areas to focus discussion on in future
meetings. Among those areas were the potential for different legal
standards for different types of inventions, the cost of prosecution under
the new rules, and issues surrounding the patenting of non-computer implemented
business methods. To address these concerns as well as to keep the
industry abreast of the USPTO changes, there is now a website
exclusively for business method patents. The next
Business Method Partnership Meeting will be on July 18, 2002 at the
PTO's offices in Washington.
Other procedural safeguards, such as a mandatory second exam for all
allowed applications, have been put in place to increase the quality of
the issued patents in this class. The second exam is intended to
ensure that the prior-art search was conducted correctly and that the scope
of the claims is appropriate. To incorporate these changes, the "Examination
Guidelines for Computer-Related Inventions" is being updated, and a larger
percentage of business method applications are going to be reviewed by
the quality control unit at the PTO (Office of Patent Quality Review.)
The International Perspective
The Patent Cooperation Treaty (and before that, the Paris Convention
Treaty) has enabled inventors to apply for patents in many countries at
the same time. This type of application results in a preliminary
prior-art search, which makes a provisional assessment of the patentability
of an invention. However, countries are not bound by that provisional
review. Typically, individual national patent offices conduct their
own assessments -- in light of their own legal standards -- of the novelty
and inventiveness of each application. In sum, substantive patent
law remains national in coverage. Consequently, the patentability
of BMPs must be determined on a country-by-country basis. Here are
the ways in which BMPs are handled in a few important jurisdictions:
The European Patent
Office (EPO) has historically not granted patents for either computer
programs or business methods. In a recent amendment
, the EPO adopted a policy (which will probably soon be implemented in
a directive) that extends patent protection to software that is of a 'technical
nature' or that has the character of a 'concrete apparatus.' Computer implemented
business methods that lack a 'technical effect' and only process data are
therefore still not patentable. But if the computer program brings
about a technical effect beyond the mere electric pulses inside the computer
-- such as the control of an industrial process or speeding data-transfer
rate -- it may be patented. See related news
(free registration required.)
In Canada business methods are not officially patentable. See
Lawson v. The Commissioner of Patents (1970), 62 C.P.R. 101. The Lawson
decision states that for an invention to be patentable it must “be one
that offers some advantage which is material, in the sense that the process
belongs to a useful art as distinct from a fine art.” The Canadian
Intellectual Property Office has interpreted this principle to mean
that computer methods or systems that are directed to a useful end result,
and are not merely directed to making calculations or to the presentation
of an algorithm and its solution, are patentable subject matter. As a result,
some patents directed to computer software inventions, including computer
implemented business methods, have been granted in Canada. A recent
decision involving a method of playing poker, suggests that a process that
(a) has a commercially useful result or effect, (b) is a practical application
of an idea, and (c) is a new and innovative method of applying a skill
or knowledge may be patented (see Progressive
Games, Inc. v. Commissioner of Patents , appeal dismissed.)
For more see Lexpert,
the website for Growling Lafleur Henderson.
Japan has also recently reexamined
its procedures for examining BMPs. The
Japanese Patent Office (JPO - take a look at its web design!) has made
its examination procedures stricter, requiring “more specific descriptions”
and a clearer description of the “inventive step” (analogous to the U.S.’s
§103 requirement of non-obviousness). Japan, like the U.S.,
is committed to increasing the “prior art” databases and utilizing industry
experts so that BMP applications with a firm foundation in the prior art,
lacking novelty and/or non-obviousness will be denied. In effect,
the JPO has said that business method patents per se are not patentable,
unless they fall within the scope of software-related inventions generally
and have the necessary inventive step required of all patentable inventions.
offices, the USPTO, EPO and JPO, which together cover about 84%
of the patents worldwide, have cooperated since 1983. They exchange views
and information as to patent administration, documentation, classification
and examination. In recent years, after concluding
that globalization of industry and trade would soon necessitate a worldwide
patent-grant system, the trilateral offices devoted considerable time and
effort to examining ways to coordinate and improve their search and examination
practices. In mid-June 2000, the trilateral offices convened in a
technical meeting to discuss and attempt to harmonize the patent practices
among themselves. At the meeting, the three offices agreed
that a “technical aspect is necessary for a computer-implemented business
method to be eligible for patenting” (either claimed expressly by the EPO
and JPO or implicitly by the USPTO) and that to “merely automate a known
human transaction process using well known automation techniques is not
patentable.” This opinion may overstate, somewhat, the extent to
which the policies and practices at the three offices are congruent. The
offices agreed that the next stage should be focusing on collaboration
in BMP prior art search. In November 2001, at the end of a program
dedicated to this end, the offices concluded
that it would be beneficial in the future to exchange information as to
search tools, strategies and databases.
| Readings | Examples
Topics | References
Home Gambling Network
Patents have always been issued and enforced on a country-by-country
basis. Since the Internet is a global medium, disparity between different
countries' standards for issuing patents give rise to difficult substantive
and jurisdictional problems. Those problems become acute when a website
in a country that does not recognize BMPs is alleged to infringe a patent
issued in a country that does recognize BMPs. In one such case, an
American judge in Nevada enforced a U.S. patent (
'268 ) against an "infringing" website that, in his view, was "targeted
to U.S. customers," even though the infringing company was based in the
Gambling Network (assignee of U.S. patent) was therefore awarded a
permanent injunction against First Live Casino (Caribbean company).
See Home Gambling Network, Inc. v First Live Casino et al., Case No. CV-S-98-1506-JBR
(RLH) (D.Nev. Feb 18, 2000). For more information on the concept
of "targeting" to obtain personal jurisdiction, please see the jurisdiction
Allan Konrad (from U.C. Berkeley) claims to own the rights by way of three
U.S. patents (
'444 , '320
, and '901
) to the manner in which interactive Websites operate. He claims
that his patented methods generically describe a computer user
requesting information from a webpage and getting it back from
a server. Therefore, he has sued 39 corporations in Texas
(possibly because Texas courts have the reputation of being sympathetic
to claims "off the beaten path" ).
Three defendants ( Motorola, Boeing, and
Eastman Kodak) are currently paying licensing fees
estimated at under $1M each because they concluded that such fees
would be cheaper (and less risky) than litigating the issue.
however, thus far has not favored Konrad. A Texas judge
ruled that his claims are narrower than he alleged and a California
judge, in a separate suit, declared his patents invalid altogether.
Both cases are currently on appeal to the Federal Circuit.
British Telecom claims to own a U.S. patent
on hyperlinking technology. The patent in controversy was filed over
20 years ago (due to a change in the patent laws, it will be enforceable
for a few more years). BT demanded payment for patent infringement
from some American Internet Service Providers (ISPs). BT filed a
suit against Prodigy (an ISP) for infringing this hyperlinking patent.
response to the suit.
Incremental software and data update
Symantec , a dominant market
player in the business of anti-virus software, owns the '531
patents on incremental software updating. The patents are the technology
behind its 'live update' feature, enabling consumers to enhance their virus
protection against new viruses incrementally by downloading small files,
rather than downloading all viruses' definitions each time anew. It is
unclear not only how Symantec's rivals, such as McAfee
, are going to react, but also other software companies, since the patents
cover a broad range of incremental software and data updating. It
is also unclear how do these patents relate to other BMPs, such as Punch
Networks ' '451
patent, which can be alleged to cover the same territory. See related
| Examples | Discussion
Topics | References
1. What could/should the U.S. Supreme Court do about BMPs?
Thus far they have not decided to hear any Internet-related patent cases.
Why do you think they haven't?
2. Sometimes parties choose to settle instead of litigate potentially
invalid patents. Is this practice socially desirable?
3. Is Jeff Bezos right? Should business
method and software patents be treated differently from other patents --
perhaps by being protected for shorter terms? Currently, the United
States recognizes two other types of patents besides the standard utility
patents: design patents (on the way a product looks, as opposed
to the way a product works, with a patent term of 14 years after
the date of issue) and plant patents (covers new varieties of asexually
reproducing plants, in conjunction with the Department of Agriculture).
Should BMPs receive similarly special treatment? Should an agency
other than the Patent Office (analogous to the Department of Agriculture)
control the issuance of such patents?
4. Imagine that it is September of 1999. You are a patent examiner at
the USPTO. You are reviewing Amazon.com's one-click
patent application (read the one-paragraph abstract under
this link.) Your search for prior art has revealed the following
(1) There is one grocery store in a small town, which allows patrons
to register their address and billing information once.
Patrons are thus able to buy items merely by presenting them to
the (only) cashier, without paying or giving any details. The
cashier, who recognizes all of her patrons, updates each patron's
record and sends accurate bills at the end of each month. (2)
It is a common practice among hotels to ask for guests' addresses
and credit-card numbers when they check in. Any goods or
services a guest subsequently orders (such as snacks from the
mini-bar, room-service, and parking privileges) are charged to
her credit card. (3) Many people use credit cards and "debit"
cards to buy groceries and other retail items. A single
"swipe" of the card is sufficient to identify such a customer
to the retail store and to initiate the billing process.
Against this backdrop, do you find Amazon's patent application
to be novel and nonobvious?
to the discussion board
Introduction | Readings
| Examples | Discussion Topics |
Primer , by NEUSTEL LAW OFFICES, Ltd. - Thorough overview
of patent law. Section titles include: "Definition of Patent",
"Patentable Subject Matter", "Who May File for Patent Protection?",
and "Content of Patent Applications."
Patent and Trademark Office General Information Concerning Patents
- This resource, created by the American Bar Association, contains a vast
amount of general information concerning the application for and granting
of patents. It is written in non-technical language given that its
stated audience is inventors, prospective applicants for patents, and students.
In particular, the resource discusses the role of the Patent and Trademark
Office, general conditions of patentability, and the parts of a patent.
Moreover, it contains an excellent discussion of the patent examination
Delphion Patent Server -
Website containing a free, fully searchable, user-friendly patent database.
Used to be IBM website.
legal Encyclopedia - Internet business method patents.
U.S. Patent Office, Laws, and Databases
United States Patent and Trademark Office
- Main Website
United States Patent
and Trademark Office - Business Method Patent Site
of Patent Examining Procedure (MPEP) - Online
version of the entire manual.
of Patent Practitioners - Website for this non-profit organization
dedicated to supporting patent practitioners and those working in the field
of patent law in matters relating to patent law, its practice, and technological
A user-friendly USPTO presentation
on patentable subject-matter in relation to computer-implemented business
at a WIPO conference as to the American perspective on business method
Protest and Opposition Sites
- Gregory Aharonian's web-site.
Protecting Software Innovation
against Patent Inflation - FFII web-site. Includes European and Japanese
Anatomy of a Trivial Patent - Short column by Richard Stallman.
League for Programming Freedom
- An MIT initiative.
Freepatents - Open Source
Absurd - Short column by Simon L. Garfinkel, Wired magazine 2.07.
In re Alappat, 33 F.3d 1526 (Fed. Cir. 1994) (en banc) - Shaped the
requirements for patentability of computer software, and served as a foundation
on which State Street Bank built.
Street Bank & Trust Co. v. Signature Financial Group, Inc, 149
F.3d 1368 (1998) - The Federal Circuit case that is generally credited
with laying the foundation for Internet patents.
AT&T Corp. v.
Excel Communications, Inc., 172 F.3d 1352 (1999) - In this post-State
Street decision, the Federal Circuit reaffirmed its State Street decision
stating specifically that "[i]n our recent decision in State Street, this
court discarded the so-called "business method" exception and reassessed
the "mathematical algorithm" exception."
In the news:
InterTrust Technologies Corp. v. Microsoft
Corp., N.D. Cal., No. C01-1640JL, filed 4/26/01: InterTrust
, holder of a patent
for secure transmission and management of proprietary content and handling
related data management rights information, claims that Microsoft infringes
its patent rights by using
similar technology in
its Media Player, Windows XP
, Office XP and its .Net initiative for
remote use of server located applications (such as calendars.) Read the
news coverage as this story unfolds: 1
, and 3
InTouch Group Inc. v. Amazon.com, Liquid Audio, Discovermusic.com, and
Entertaindom (part of Time Warner), N.D. Cal., No. C-00-1156-DLJ, filed
April 2000. InTouch, holder of the '157
patents, which cover consumers' sampling of music online, sues for its
patents' infringement. Amazon.com is among the defendants since it allows
consumers, in their process of buying CDs online, to sample them.
So far the court has ruled that the term "review a portion" should be interpreted
according to Amazon's view (substantially reduced duration) and not InTouch's
(reduced quality of a song's full version.) Read related news 1
, 2 .
Concerns When Pursuing Foreign Patents In The Computer Arts - Everything
you've ever wanted to know about filing for a patent in a foreign country.
Patent Cooperation Treaty (PCT) Principles - Section 1801 of the Manual
of Patent Examining Procedure describes, in the words of the Patent and
Trademark Office, the general principles behind the PCT.
Facts About the Patent Cooperation Treaty (PCT) -
Information on the PCT from the U.S. Patent and Trademark Office's site
Patent Filing - This small page summarizes the international and European
UK Patent Office
- Which is in the process of examining
its policy towards business method patents
to other countries' patent offices , and their directory
Law firm's international
links according to countries
Introduction | Readings
Topics | References