MPEP § 2147 — Biotechnology Process Applications; Pre-AIA 35 U.S.C. 103(b) (Annotated Rules)

§2147 Biotechnology Process Applications; Pre-AIA 35 U.S.C. 103(b)

USPTO MPEP version: BlueIron's Update: 2026-01-10

This page consolidates and annotates all enforceable requirements under MPEP § 2147, 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.

Biotechnology Process Applications; Pre-AIA 35 U.S.C. 103(b)

This section addresses Biotechnology Process Applications; Pre-AIA 35 U.S.C. 103(b). Primary authority: 35 U.S.C. 100, 35 U.S.C. 103(b), and 35 U.S.C. 103(a). Contains: 2 requirements, 1 guidance statement, 1 permission, and 8 other statements.

Key Rules

Topic

Obviousness Under AIA (MPEP 2158)

8 rules
StatutoryInformativeAlways
[mpep-2147-7e70f3a9f371c66e98d2286f]
Pre-AIA 35 U.S.C. 103(b) Applies to Biotechnological Processes Only
Note:
This rule restricts the application of Pre-AIA 35 U.S.C. 103(b) to biotechnological processes, limiting its use for rejecting process claims involving nonobvious biotechnological compositions.

Pre-AIA 35 U.S.C. 103(b) is applicable to biotechnological processes only. Pre-AIA 35 U.S.C. 103(b) precludes a rejection of process claims which involve the use or making of certain nonobvious biotechnological compositions of matter under pre-AIA 35 U.S.C. 103(a). Only applications subject to pre-AIA 35 U.S.C. 102 are subject to pre-AIA 35 U.S.C. 103(b). See MPEP § 2159.

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StatutoryInformativeAlways
[mpep-2147-380e06918d1b473bf5b6b04a]
Nonobvious Biotechnological Compositions in Process Claims Not Rejected Under Pre-AIA 103(a)
Note:
Process claims involving nonobvious biotechnological compositions are not rejected under pre-AIA 35 U.S.C. 103(a) if subject to pre-AIA 35 U.S.C. 102 conditions.

Pre-AIA 35 U.S.C. 103(b) is applicable to biotechnological processes only. Pre-AIA 35 U.S.C. 103(b) precludes a rejection of process claims which involve the use or making of certain nonobvious biotechnological compositions of matter under pre-AIA 35 U.S.C. 103(a). Only applications subject to pre-AIA 35 U.S.C. 102 are subject to pre-AIA 35 U.S.C. 103(b). See MPEP § 2159.

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StatutoryInformativeAlways
[mpep-2147-59a39449f8a7435103d67b03]
Applications Subject to Pre-AIA 102 Must Follow Pre-AIA 103(b)
Note:
Only applications subject to pre-AIA 35 U.S.C. 102 must comply with the conditions of pre-AIA 35 U.S.C. 103(b), which applies specifically to biotechnological processes.

Pre-AIA 35 U.S.C. 103(b) is applicable to biotechnological processes only. Pre-AIA 35 U.S.C. 103(b) precludes a rejection of process claims which involve the use or making of certain nonobvious biotechnological compositions of matter under pre-AIA 35 U.S.C. 103(a). Only applications subject to pre-AIA 35 U.S.C. 102 are subject to pre-AIA 35 U.S.C. 103(b). See MPEP § 2159.

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StatutoryInformativeAlways
[mpep-2147-b67fc86541ee639fdedd094c]
Requirement for Biotechnological Process and Composition of Matter
Note:
The rule requires that a biotechnological process and its composition of matter must be in the same or separate applications with the same effective filing date, owned by the same person, and have related patents expiring on the same date.
Pre-AIA 35 U.S.C. 103(b) requires that:
  • (A) the biotechnological process and composition of matter be contained in either the same application or in separate applications having the same effective filing date;
  • (B) both the biotechnological process and composition of matter be owned or subject to an assignment to the same person at the time the process was invented;
  • (C) a patent issued on the process also contain the claims to the composition of matter used in or made by the process, or, if the process and composition of matter are in different patents, the patents expire on the same date;
  • (D) the biotechnological process falls within the definition set forth in pre-AIA 35 U.S.C. 103(b); and
  • (E) a timely election be made to proceed under the provisions of pre-AIA 35 U.S.C. 103(b).
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StatutoryInformativeAlways
[mpep-2147-59636195e541ebb1537f1b56]
Timely Election Required for Pre-AIA 103(b)
Note:
A timely election must be made to proceed under the provisions of pre-AIA 35 U.S.C. 103(b).

Pre-AIA 35 U.S.C. 103(b) requires that:

(E) a timely election be made to proceed under the provisions of pre-AIA 35 U.S.C. 103(b).

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StatutoryRequiredAlways
[mpep-2147-780d0d05e61aa1532e8829cd]
Petition Required for Pre-AIA 103(b) Election
Note:
A petition must be filed under 37 CFR 1.182 to proceed with an election under pre-AIA 35 U.S.C. 103(b), establishing that all requirements have been satisfied.

An election to proceed under pre-AIA 35 U.S.C. 103(b) shall be made by way of petition under 37 CFR 1.182. The petition must establish that all the requirements set forth in pre-AIA 35 U.S.C. 103(b) have been satisfied.

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StatutoryRequiredAlways
[mpep-2147-0426e618b8a936b85b609c3e]
Petition Must Establish Pre-AIA 103(b) Requirements
Note:
The petition must demonstrate that all conditions specified in pre-AIA 35 U.S.C. 103(b) have been met.

An election to proceed under pre-AIA 35 U.S.C. 103(b) shall be made by way of petition under 37 CFR 1.182. The petition must establish that all the requirements set forth in pre-AIA 35 U.S.C. 103(b) have been satisfied.

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StatutoryPermittedAlways
[mpep-2147-95b689e21d282ef15b4466b3]
Entry of Process Claims Corresponding to Composition of Matter Claim Permitted
Note:
In an application with at least one composition of matter claim not rejected under pre-AIA 35 U.S.C. 102 or 103(a), a pre-AIA 35 U.S.C. 103(b) election may be made by submitting a petition and an amendment requesting entry of process claims corresponding to the composition of matter claim.

In an application where at least one composition of matter claim has not been rejected under pre-AIA 35 U.S.C. 102 or 103(a), a pre-AIA 35 U.S.C. 103(b) election may be made by submitting the petition and an amendment requesting entry of process claims which correspond to the composition of matter claim.

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Topic

Assignee as Applicant Signature

2 rules
StatutoryInformativeAlways
[mpep-2147-e5d940c4575efd7a32f591b8]
Patenting Conventional Processes Using Nonobvious Products
Note:
An otherwise conventional process can be patented if it uses a nonobvious product, as per Federal Circuit decisions in Ochiai and Brouwer.

See MPEP § 2116.01 for a discussion of the Federal Circuit’s decisions in In re Ochiai, 71 F.3d 1565, 37 USPQ 1127 (Fed. Cir. 1995) and In re Brouwer, 77 F.3d 422, 37 USPQ2d 1663 (Fed. Cir. 1996) which address the general issue of whether an otherwise conventional process could be patented if it were limited to making or using a nonobvious product. In view of the Federal Circuit’s decisions in Ochiai and Brouwer, an applicant’s need to rely upon pre-AIA 35 U.S.C. 103(b) should be rare. See also 1184 OG 86 (Comm’r Pat. 1996). See 35 U.S.C. 282 for the effect of a determination of nonobviousness under pre-AIA 35 U.S.C. 103(b)(1) on the presumption of validity.

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StatutoryRecommendedAlways
[mpep-2147-256cdbc0c85daf76381a39d8]
Rarely Rely on Pre-AIA 103(b)
Note:
An applicant should rarely need to rely on pre-AIA 35 U.S.C. 103(b) for patentability, as per Federal Circuit decisions in Ochiai and Brouwer.

See MPEP § 2116.01 for a discussion of the Federal Circuit’s decisions in In re Ochiai, 71 F.3d 1565, 37 USPQ 1127 (Fed. Cir. 1995) and In re Brouwer, 77 F.3d 422, 37 USPQ2d 1663 (Fed. Cir. 1996) which address the general issue of whether an otherwise conventional process could be patented if it were limited to making or using a nonobvious product. In view of the Federal Circuit’s decisions in Ochiai and Brouwer, an applicant’s need to rely upon pre-AIA 35 U.S.C. 103(b) should be rare. See also 1184 OG 86 (Comm’r Pat. 1996). See 35 U.S.C. 282 for the effect of a determination of nonobviousness under pre-AIA 35 U.S.C. 103(b)(1) on the presumption of validity.

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Topic

Statutory Authority for Examination

1 rules
StatutoryInformativeAlways
[mpep-2147-7bcdc4ca0084f52851a32859]
Check for FITF Provisions Before Examination
Note:
Ensure that examination under the first inventor to file provisions of the AIA is determined before proceeding with the application.

[Editor Note: This MPEP section is not 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.]

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Topic

Issue Fees

1 rules
StatutoryInformativeAlways
[mpep-2147-b0e9d3543d0b2c8b1931ba55]
Timely Election Requirement for Composition Claims
Note:
An election must be made no later than the earlier of paying the issue fee or filing an appeal brief in an application containing a composition claim not rejected under pre-AIA 35 U.S.C. 102 or 103(a).

An election will normally be considered timely if it is made no later than the earlier of either the payment of the issue fee or the filing of an appeal brief in an application which contains a composition of matter claim which has not been rejected under pre-AIA 35 U.S.C. 102 or 103(a).

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Topic

Reissue Fees

1 rules
StatutoryPermittedAlways
[mpep-2147-dee555b7c51428a6d1f2021e]
Election Requirement for Process Claims Under Pre-AIA 35 U.S.C. 103(b)
Note:
For applications pending on or after November 1, 1995, with issue fee paid before March 26, 1996, the election requirement under pre-AIA 35 U.S.C. 103(b) is satisfied if conditions of 37 CFR 1.312(b) are met.

For applications pending on or after November 1, 1995, in which the issue fee has been paid prior to March 26, 1996, the timeliness requirement for an election under pre-AIA 35 U.S.C. 103(b) will be considered satisfied if the conditions of 37 CFR 1.312(b) are met. However, if a patent is granted on an application entitled to the benefit of pre-AIA 35 U.S.C. 103(b) without an election having been made as a result of error, patentees may file a reissue application to permit consideration of process claims which qualify for pre-AIA 35 U.S.C. 103(b) treatment. See MPEP § 1412.02, subsection II.

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Citations

Primary topicCitation
Statutory Authority for Examination35 U.S.C. § 100
Issue Fees
Obviousness Under AIA (MPEP 2158)
35 U.S.C. § 102
Obviousness Under AIA (MPEP 2158)35 U.S.C. § 103(a)
Assignee as Applicant Signature
Obviousness Under AIA (MPEP 2158)
Reissue Fees
35 U.S.C. § 103(b)
Assignee as Applicant Signature35 U.S.C. § 103(b)(1)
Assignee as Applicant Signature35 U.S.C. § 282
Obviousness Under AIA (MPEP 2158)37 CFR § 1.182
Reissue Fees37 CFR § 1.312(b)
Reissue FeesMPEP § 1412.02
Assignee as Applicant SignatureMPEP § 2116.01
Statutory Authority for ExaminationMPEP § 2150
Obviousness Under AIA (MPEP 2158)
Statutory Authority for Examination
MPEP § 2159
Assignee as Applicant SignatureIn re Brouwer, 77 F.3d 422, 37 USPQ2d 1663 (Fed. Cir. 1996)
Assignee as Applicant SignatureIn re Ochiai, 71 F.3d 1565, 37 USPQ 1127 (Fed. Cir. 1995)

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: 2026-01-10