MPEP § 2133.03(e) — Permitted Activity; Experimental Use (Annotated Rules)

§2133.03(e) Permitted Activity; Experimental Use

USPTO MPEP version: BlueIron's Update: 2026-01-17

This page consolidates and annotates all enforceable requirements under MPEP § 2133.03(e), including statutory authority, regulatory rules, examiner guidance, and practice notes. It is provided as guidance, with links to the ground truth sources. This is information only, it is not legal advice.

Permitted Activity; Experimental Use

This section addresses Permitted Activity; Experimental Use. Primary authority: 35 U.S.C. 100, 35 U.S.C. 102, and 35 U.S.C. 102(b). Contains: 2 requirements, 1 permission, and 6 other statements.

Key Rules

Topic

Commercial vs. Experimental Purpose

5 rules
StatutoryInformativeAlways
[mpep-2133-03-e-b3f16190e3b592a645828f65]
Primary Purpose Must Be Experimentation
Note:
The primary purpose of an inventor's sale must be experimentation, not commercial exploitation, to qualify as a permitted activity under the experimental use doctrine.

The question posed by the experimental use doctrine is “whether the primary purpose of the inventor at the time of the sale, as determined from an objective evaluation of the facts surrounding the transaction, was to conduct experimentation.” Allen Eng’g Corp. v. Bartell Indus., Inc., 299 F.3d 1336, 1354, 63 USPQ2d 1769, 1780 (Fed. Cir. 2002) (quoting EZ Dock v. Schafer Sys., Inc., 276 F.3d 1347, 1356-57, 61 USPQ2d 1289, 1295-96 (Fed. Cir. 2002)) (Linn, J., concurring). Experimentation must be the primary purpose and any commercial exploitation must be incidental in order for the sale to be a permitted activity that does not create a bar under pre-AIA 35 U.S.C. 102(b).

Jump to MPEP SourceCommercial vs. Experimental PurposeExperimental Use Exception (MPEP 2133.03(e))Public Use and On-Sale Bar (MPEP 2133.03)
StatutoryRequiredAlways
[mpep-2133-03-e-5f487138b429d7df15225339]
Primary Purpose Must Be Experimentation
Note:
The sale is permitted if experimentation is the primary purpose and commercial exploitation is incidental.

The question posed by the experimental use doctrine is “whether the primary purpose of the inventor at the time of the sale, as determined from an objective evaluation of the facts surrounding the transaction, was to conduct experimentation.” Allen Eng’g Corp. v. Bartell Indus., Inc., 299 F.3d 1336, 1354, 63 USPQ2d 1769, 1780 (Fed. Cir. 2002) (quoting EZ Dock v. Schafer Sys., Inc., 276 F.3d 1347, 1356-57, 61 USPQ2d 1289, 1295-96 (Fed. Cir. 2002)) (Linn, J., concurring). Experimentation must be the primary purpose and any commercial exploitation must be incidental in order for the sale to be a permitted activity that does not create a bar under pre-AIA 35 U.S.C. 102(b).

Jump to MPEP SourceCommercial vs. Experimental PurposePublic Use and On-Sale Bar (MPEP 2133.03)Novelty / Prior Art
StatutoryRequiredAlways
[mpep-2133-03-e-d53cc22b093c07a561166413]
Commercial Exploitation Must Be Incidental to Experimentation
Note:
If commercial exploitation occurs, it must be secondary to the primary purpose of perfecting the invention through experimentation.

If the use or sale was experimental, there is no bar under pre-AIA 35 U.S.C. 102(b). “A use or sale is experimental for purposes of [pre-AIA] section 102(b) if it represents a bona fide effort to perfect the invention or to ascertain whether it will answer its intended purpose.… If any commercial exploitation does occur, it must be merely incidental to the primary purpose of the experimentation to perfect the invention.” LaBounty Mfg. v. United States Int’l Trade Comm’n, 958 F.2d 1066, 1071, 22 USPQ2d 1025, 1028 (Fed. Cir. 1992) (quoting Pennwalt Corp. v. Akzona Inc., 740 F.2d 1573, 1581, 222 USPQ 833, 838 (Fed. Cir. 1984)). “The experimental use exception…does not include market testing where the inventor is attempting to gauge consumer demand for his claimed invention. The purpose of such activities is commercial exploitation and not experimentation.” In re Smith, 714 F.2d 1127, 1134, 218 USPQ 976, 983 (Fed. Cir. 1983).

Jump to MPEP SourceCommercial vs. Experimental PurposePublic Use and On-Sale Bar (MPEP 2133.03)Determining Whether Application Is AIA or Pre-AIA
StatutoryInformativeAlways
[mpep-2133-03-e-76a41d9aa656f1f4e19e9c3c]
Experimental Use Does Not Bar Public Disclosure If Aimed at Perfecting Invention
Note:
This rule states that the public use or sale of an invention does not bar it from being patented if such use was experimental and aimed at perfecting the invention, provided any commercial exploitation is incidental.

If the use or sale was experimental, there is no bar under pre-AIA 35 U.S.C. 102(b). “A use or sale is experimental for purposes of [pre-AIA] section 102(b) if it represents a bona fide effort to perfect the invention or to ascertain whether it will answer its intended purpose.… If any commercial exploitation does occur, it must be merely incidental to the primary purpose of the experimentation to perfect the invention.” LaBounty Mfg. v. United States Int’l Trade Comm’n, 958 F.2d 1066, 1071, 22 USPQ2d 1025, 1028 (Fed. Cir. 1992) (quoting Pennwalt Corp. v. Akzona Inc., 740 F.2d 1573, 1581, 222 USPQ 833, 838 (Fed. Cir. 1984)). “The experimental use exception…does not include market testing where the inventor is attempting to gauge consumer demand for his claimed invention. The purpose of such activities is commercial exploitation and not experimentation.” In re Smith, 714 F.2d 1127, 1134, 218 USPQ 976, 983 (Fed. Cir. 1983).

Jump to MPEP SourceCommercial vs. Experimental PurposeDetermining Whether Application Is AIA or Pre-AIAExperimental Use Exception (MPEP 2133.03(e))
StatutoryInformativeAlways
[mpep-2133-03-e-d209227bdc02783c06bf4a05]
Market Testing Not Experimental Use
Note:
The experimental use exception does not apply to market testing aimed at gauging consumer demand, as the primary purpose is commercial exploitation.

If the use or sale was experimental, there is no bar under pre-AIA 35 U.S.C. 102(b). “A use or sale is experimental for purposes of [pre-AIA] section 102(b) if it represents a bona fide effort to perfect the invention or to ascertain whether it will answer its intended purpose.… If any commercial exploitation does occur, it must be merely incidental to the primary purpose of the experimentation to perfect the invention.” LaBounty Mfg. v. United States Int’l Trade Comm’n, 958 F.2d 1066, 1071, 22 USPQ2d 1025, 1028 (Fed. Cir. 1992) (quoting Pennwalt Corp. v. Akzona Inc., 740 F.2d 1573, 1581, 222 USPQ 833, 838 (Fed. Cir. 1984)). “The experimental use exception…does not include market testing where the inventor is attempting to gauge consumer demand for his claimed invention. The purpose of such activities is commercial exploitation and not experimentation.” In re Smith, 714 F.2d 1127, 1134, 218 USPQ 976, 983 (Fed. Cir. 1983).

Jump to MPEP SourceCommercial vs. Experimental PurposeDetermining Whether Application Is AIA or Pre-AIAExperimental Use Exception (MPEP 2133.03(e))
Topic

AIA vs Pre-AIA Practice

2 rules
StatutoryInformativeAlways
[mpep-2133-03-e-2618b58b2492021c81db078b]
Experimental Use Exception Under Pre-AIA 102(b)
Note:
This rule permits the use or sale of an invention during experimentation without barring it under pre-AIA 35 U.S.C. 102(b), provided such activities are bona fide efforts to perfect the invention or ascertain its intended purpose.

If the use or sale was experimental, there is no bar under pre-AIA 35 U.S.C. 102(b). “A use or sale is experimental for purposes of [pre-AIA] section 102(b) if it represents a bona fide effort to perfect the invention or to ascertain whether it will answer its intended purpose.… If any commercial exploitation does occur, it must be merely incidental to the primary purpose of the experimentation to perfect the invention.” LaBounty Mfg. v. United States Int’l Trade Comm’n, 958 F.2d 1066, 1071, 22 USPQ2d 1025, 1028 (Fed. Cir. 1992) (quoting Pennwalt Corp. v. Akzona Inc., 740 F.2d 1573, 1581, 222 USPQ 833, 838 (Fed. Cir. 1984)). “The experimental use exception…does not include market testing where the inventor is attempting to gauge consumer demand for his claimed invention. The purpose of such activities is commercial exploitation and not experimentation.” In re Smith, 714 F.2d 1127, 1134, 218 USPQ 976, 983 (Fed. Cir. 1983).

Jump to MPEP SourceAIA vs Pre-AIA PracticeNovelty / Prior ArtCommercial vs. Experimental Purpose
StatutoryInformativeAlways
[mpep-2133-03-e-3058b70b07097dedc5e5e9a3]
Experimental Use Exception for Pre-AIA Section 102(b)
Note:
This rule permits use or sale of an invention during pre-AIA patent examination if it is part of a genuine effort to improve the invention or test its functionality, provided such commercial exploitation is incidental.

If the use or sale was experimental, there is no bar under pre-AIA 35 U.S.C. 102(b). “A use or sale is experimental for purposes of [pre-AIA] section 102(b) if it represents a bona fide effort to perfect the invention or to ascertain whether it will answer its intended purpose.… If any commercial exploitation does occur, it must be merely incidental to the primary purpose of the experimentation to perfect the invention.” LaBounty Mfg. v. United States Int’l Trade Comm’n, 958 F.2d 1066, 1071, 22 USPQ2d 1025, 1028 (Fed. Cir. 1992) (quoting Pennwalt Corp. v. Akzona Inc., 740 F.2d 1573, 1581, 222 USPQ 833, 838 (Fed. Cir. 1984)). “The experimental use exception…does not include market testing where the inventor is attempting to gauge consumer demand for his claimed invention. The purpose of such activities is commercial exploitation and not experimentation.” In re Smith, 714 F.2d 1127, 1134, 218 USPQ 976, 983 (Fed. Cir. 1983).

Jump to MPEP SourceAIA vs Pre-AIA PracticeNovelty / Prior ArtCommercial vs. Experimental Purpose
Topic

On Sale Under AIA (MPEP 2152.02(d))

1 rules
StatutoryPermittedAlways
[mpep-2133-03-e-2f691366ba9a3ad2387323d1]
Requirement for Determining Public Use and On Sale Under AIA
Note:
This rule outlines the conditions under which an invention can be considered publicly used or on sale, affecting patentability under the AIA's 35 U.S.C. 102.

[Editor Note: This MPEP section may be applicable to applications subject to examination under the first inventor to file (FITF) provisions of the AIA as set forth in 35 U.S.C. 100 (note). See MPEP § 2159 et seq. to determine whether an application is subject to examination under the FITF provisions, and MPEP § 2150 et seq. for examination of applications subject to those provisions. See MPEP § 2152.02(c) through (e) for a detailed discussion of the public use and on sale provisions of AIA 35 U.S.C. 102.]

Jump to MPEP SourceOn Sale Under AIA (MPEP 2152.02(d))Public Use Under AIA (MPEP 2152.02(c))AIA 102(a)(1) – Prior Art Categories (MPEP 2152.02)
Topic

Experimental Use Exception (MPEP 2133.03(e))

1 rules
StatutoryInformativeAlways
[mpep-2133-03-e-5e287d7a6f3ee8c70183366b]
Primary Purpose of Sale Must Be Experimentation
Note:
The sale is permitted if the primary purpose at the time was to conduct experimentation, not commercial exploitation.

The question posed by the experimental use doctrine is “whether the primary purpose of the inventor at the time of the sale, as determined from an objective evaluation of the facts surrounding the transaction, was to conduct experimentation.” Allen Eng’g Corp. v. Bartell Indus., Inc., 299 F.3d 1336, 1354, 63 USPQ2d 1769, 1780 (Fed. Cir. 2002) (quoting EZ Dock v. Schafer Sys., Inc., 276 F.3d 1347, 1356-57, 61 USPQ2d 1289, 1295-96 (Fed. Cir. 2002)) (Linn, J., concurring). Experimentation must be the primary purpose and any commercial exploitation must be incidental in order for the sale to be a permitted activity that does not create a bar under pre-AIA 35 U.S.C. 102(b).

Jump to MPEP SourceExperimental Use Exception (MPEP 2133.03(e))Commercial vs. Experimental PurposePublic Use and On-Sale Bar (MPEP 2133.03)

Citations

Primary topicCitation
On Sale Under AIA (MPEP 2152.02(d))35 U.S.C. § 100
On Sale Under AIA (MPEP 2152.02(d))35 U.S.C. § 102
AIA vs Pre-AIA Practice
Commercial vs. Experimental Purpose
Experimental Use Exception (MPEP 2133.03(e))
35 U.S.C. § 102(b)
On Sale Under AIA (MPEP 2152.02(d))MPEP § 2150
On Sale Under AIA (MPEP 2152.02(d))MPEP § 2152.02(c)
On Sale Under AIA (MPEP 2152.02(d))MPEP § 2159
AIA vs Pre-AIA Practice
Commercial vs. Experimental Purpose
In re Smith, 714 F.2d 1127, 1134, 218 USPQ 976, 983 (Fed. Cir. 1983)
AIA vs Pre-AIA Practice
Commercial vs. Experimental Purpose
quoting Pennwalt Corp. v. Akzona Inc., 740 F.2d 1573, 1581, 222 USPQ 833, 838 (Fed. Cir. 1984)

Source Text from USPTO’s MPEP

This is an exact copy of the MPEP from the USPTO. It is here for your reference to see the section in context.

BlueIron Last Updated: 2026-01-17