The handling of the patent system is at variance in the American system with that in the European Union's system, where the American system began to allow software protection under its patent system in addition to copyright protection while the European Union's Patent Office accepts this tendency some member States reject it. This affects negatively the level of protection and its nature, which should be available in a suitable and balanced manner between the different legal systems due to the nature of software as a countries' trans-border product. Thus, this research study calls for a special system of protection since the two major intellectual property systems, namely copyright and patent, do not provide separately the required protection to software and contradicts the joint protection decision, which is due to the different nature of both systems.
Abdullah, Mohammed Hassan
"Software Patent in U.S. Law,"
Journal Sharia and Law: Vol. 2011
, Article 2.
Available at: https://scholarworks.uaeu.ac.ae/sharia_and_law/vol2011/iss47/2