文档介绍：The European Patent Convention (EPC) 欧洲专利公约( EPC ) Currently, for ICT-related inventions the two most important areas to obtain patent protection are probably the United States and West-European countries. Twenty European countries are currently member to the European Patent Convention, and it is possible to obtain patent protection in those countries through a single procedure before the European Patent Office. 目前,与信息通讯技术相关的两个最重要的领域的发明, 其专利的保护一般都是通过进入美国和西欧等国家获取的。欧洲专利公约当前加入了 20 个新成员国,并使申请人在向欧洲专利局提交申请之前能够通过某单一程序向所在成员国申请专利保护。 While quite a few aspects of patent law have been harmonized internationally (not in the least due to treaties like the Patent Cooperation Treaty or TRIPS), there still are many important differences between the two systems. This article discusses several of them. 虽然,专利法中有相当几个方面的内容已经做了国际化的协调与统一(不完全与《专利合作条约》以及《与贸易有关的知识产权协议》相同), 但美欧两个系统间仍旧存在重要的差异, 本文就其差异做出以下几点概括。 First to file versus first to invent 先申请制 VS 先发明制 When two people apply for a patent on the same invention, the first person to have filed his application will get the patent (assuming the invention is patentable, of course). This holds even if the second person did in e up with the invention first. The only thing that counts is the filing date. 若两名当事人就同一个发明分别申请专利权, 那么率先提出申请者将获得该专利权( 假设该发明确认是具有可专利性的)。由此认为, 尽管此项发明是由第二个申请人先提出的, 但仅以提交申请的日期为准。 In the USA, a slightly different approach is used. In case of