A Green Industry Guide To Plant Patents And Other Intellectual Property .
PB 1882A Green Industry Guide to Plant Patentsand Other Intellectual Property RightsAmy Fulcher, Extension Specialist and Associate ProfessorLauren Fessler, Extension AssistantTammy Stackhouse, former Extension Program AssistantDepartment of Plant SciencesA GREEN INDUSTRY GUIDE TO PLANT PATENTS AND OTHER INTELLECTUAL PROPERTY RIGHTS1
IntroductionWalk into any garden center today and you are likely tosee shrubs with large, colorful tags featuring the plantin bloom and a catchy name. If you look closely, youmight notice “PP” and a series of numbers or “PPAF.”What does this mean for landscape contractors, gardencenter owners or nursery producers? In this publication,we will explain the concept of intellectual propertyand the related concept of copyright and trademarkprotection, how intellectual property affects day-to-daybusiness, and ultimately how the use of brandingprograms has changed the Green Industry.The USDA defines intellectual property rights as“the legal protection for inventions, including newtechnologies or new organisms (such as new plantvarieties). The owner of these rights can control theiruse and earn the rewards for their use. This encouragesfurther innovation and creativity for the benefit of us all.Intellectual property rights protection includes varioustypes of patents, trademarks, and copyrights.” Fornurseries, the term intellectual property rights appliesto plant breeder rights, which primarily include patentsand trademarks. Different classifications of intellectualproperty have different requirements and regulationsassociated with them. Understanding these differencesis important in order to benefit from the advantagesof protected plants while remaining compliant andavoiding monetary penalties or legal action.Plant PatentsPlant patents are granted to those who discoveror invent a new and distinct cultivar and asexuallyreproduce it. Plant patents allow the patent holder toprevent others from asexually reproducing the newplant without first entering into a licensing agreement.Plant patents protect the entirety of the plant and lastfor 20 years. The limited life of a patent contributedto the widespread adoption of trademarking plantsin recent years. Patent lifespan is particularly relevantfor trees, given that they may not gain market shareas quickly as shrubs, which develop their highlymarketable characteristics in a shorter period of timethan trees, and those desirable attributes are oftenvisible at the point of sale.The following are requirements for receiving aplant patent:1. The plant can be produced asexually.2. The plant was invented or discovered, and ifdiscovered, it was in a cultivated area (not the wild);however, the person who identified the plant doesnot need to be the owner of the cultivated land onwhich the plant was discovered.23. The plant is not excluded from the statute;specifically, the part of the plant used for asexualreproduction is not a tuber food part (e.g., potato,Jerusalem artichoke).4. The person, company or nonprofit entity filing thepatent invented or discovered the plant and asexuallyreproduced it.5. The plant has not been patented, in public use or forsale, or otherwise available to the public more thanone year prior to the effective filing date.6. The plant is novel and has at least one inherent,distinguishing characteristic (i.e., beyond that whichis induced by varying environmental conditions).7. The invention would not have been obvious to askilled horticulturist.Presentations, trade show demonstrations, lectures,statements broadcast on the radio, and online videosand other web-based content constitute making theplant available to the public.What if ?I remove suckers from patented brambles andgive them away, is this infringement?Planting, selling or giving away the plants wouldbe considered infringement; you would be liablefor damages and could incur legal penalties.I prune suckers from patented brambles andsome of them in the cull pile take root, can Ibe penalized?This would still be considered infringement eventhough the reproduction is unintentional.What would happen if I allowed my patentedbrambles to go to seed and instead of buyingplants the following year, I plant the seeds fromthe previous year?This is NOT considered infringement BUT there isthe risk of claims of infringement if the resultingplants are similar to the patented parent plants.Did you know?According to the 8th International Code ofNomenclature for Cultivated Plants, the cultivarname doesn’t have to be an existing word; it canbe developed solely for the purpose of creatinga cultivar name. The cultivar name can also be acode of up to 10 characters.A GREEN INDUSTRY GUIDE TO PLANT PATENTS AND OTHER INTELLECTUAL PROPERTY RIGHTS
A plant patent may refer to one or more novelcharacteristics, but is limited to one claim. The entiretyof the plant is protected, but not the reproductivesubparts of the plant (i.e., seeds, flowers and fruit arenot protected by plant patents) such that patentedplants can be used by other plant breeders to producenew hybrids. Under a plant patent, the owner has theexclusive right to make, use, offer for sale, sell orimport the plant. Patent owners also have the right “toassign, or transfer by succession, the patent and toconclude licensing contracts.”Patent owners are not required to label their patentedplants, but if they don’t label them, they cannot getinfringement damages for the time they were notlabeled. If they were to notify a grower that they hold apatent for plants the grower was producing, the patentholder can collect damages if that grower continuesto grow the plant, but they can’t take damages fromthe grower for the time prior to being notified as aninfringer. For plants that are patented or in the processof being patented, the label will typically have PP for“plant patent,” then a series of numbers or PPAF for“plant patent applied for” (Figure 1). More than likely,if you buy plants as a nursery owner, you will knowit is patented by a license agreement or royalty fee,increasing the plant price as well as an additionalprice for tags and, in most cases, containers in whichthe plants must be sold. Verify with your supplier ifyou have any doubt as to whether or not a plant ispatented. As you will see in Plant Patent Case Study 2,finding out after the fact can be costly, even if a groweris not at fault.Figure 1. “PP” followed by a series of numbers or “PPAF” may be found onlabels and indicate Plant Patent and Plant Patent Applied For, respectively.Whenever someone asexually reproduces a patentedplant without permission, it qualifies as infringement.Unauthorized asexual reproduction is infringement, evenif the reproduction is unintentional (Figure 2). Sexualreproduction is not an infringement on plants with acurrent patent, but if the resulting plants are almostidentical to a patented parent plant, there’s a risk thepatent owners could claim infringement, which maynecessitate an expensive legal defense.Key aspects of plant patents center on protecting plants(intellectual property) when the plant is discovered ina cultivated area and thereafter asexually reproduced.Proper notification or labels are needed in order tocollect damages if infringement occurs. Last, the patentowner has exclusive right to make, use, offer for sale,sell or import the plant, but they can transfer the patentand can license its sales to others. Sexual reproductionis not protected by current patent law.Figure 2. Even unintended propagation, such as when a blackberry caneroots, is technically a patent infringement.A GREEN INDUSTRY GUIDE TO PLANT PATENTS AND OTHER INTELLECTUAL PROPERTY RIGHTS3
Plant Patent Case Study 1Mark works at Torchbearer Nursery and takes a plant home that is patented. He then roots cuttings ofthat plant. He pots them and sells them under a different name. Someone notices that the plant lookslike Torchbearer Nursery’s patented plant, and Torchbearer Nursery sues Mark for patent infringement.Torchbearer Nursery files for “equitable relief.” Mark must stop selling plants until a decision has been made.Torchbearer Nursery gathers proof that the plant was stolen (i.e., genetic testing or phenotypic characteristicmeasurements) and presents it in court. The judge finds Mark guilty and determines that he owes damages inthe form of royalties, estimated profit lost, and any attorney’s fees.Plant Patent Case Study 2Maria buys tissue culture-produced liners. There is no tag denoting that the plant is patented nor an item inthe invoice indicating a royalty fee. Maria takes cuttings from these liners, and after growing them to a #3size, sells both the purchased and propagated plants. Maria is notified that the plant is patented and stopsreproducing and selling the plant. Despite existing orders and the labor and other inputs invested in growingthese plants, Maria cannot sell any of her inventory. However, Maria is not responsible for damages since shewas not initially notified of their status as patented and stopped selling the plants immediately after beingnotified. If Maria had continued to sell the plants after being notified, she would be liable for damages.Utility PatentsUtility patents are another form of federal intellectualproperty protection available for plants and plantmaterials. Utility patents are typically used fortransgenic or genetically engineered plants but can beused for other plants, although it’s rare. Utility patentsprotect specific attributes of the plants, such as adisease-resistance trait. Unlike plant patents, utilitypatents are not limited to a single claim. To receive autility patent, a plant must be considered a unique andnew invention, and the specifications that describethe invention must be written in such a way that thoseskilled in the field can learn how to duplicate thatspecific invention. Thus, a utility patent holder is tradingprotection for a limited time with full disclosure to thepublic on how to replicate the invention. With utilitypatents, the reproduction strategy does not matter (i.e.,the trait is protected from any unlicensed reproduction).Utility patent protections last 20 years, yet can berenewed. While this may seem irrelevant to nurserymanagement at the moment, transgenics were recentlyused to develop an American chestnut tree resistant toblight, which is awaiting approval.There are three requirements for a plant trait to beeligible for a utility patent:1. The plant is an invention with a detailed description.2. The plant and trait of interest are novel.3. The plant has not been available to the public, sharedwith, or sold to a third party prior to patenting.4As with plant patents, various forms of in-person ordigital educational presentations or promotions andother content constitute making the plant available tothe public.In some cases, utility patents also require a depositof seed to “enable” their patent application. Uponreceiving the patent, the owner may exclude othersfrom making, using, selling, importing or offering tosell the invention. Doing any of these actions wouldbe infringement and the owner can recover damages.A plant protected under a utility patent can be soldby a licensed propagator in seed form and the buyercan sell the resulting plants, but they cannot usethose plants as a source for seeds. The resulting seedis protected and cannot be resold, given away orreplanted. Remember, the invention is the trait, so theutility patent covers more than direct descendants. Thepatent will cover any plants with that trait even if thetraits were developed independently with no intent toinfringe. This stipulation gives utility patents a broaderscope of reach than plant patents. In some cases, thiswill increase the commercial value. Additionally, theutility patent holder can sell the rights to the trait toanother breeder or to a company for a set dollar figureor portion of royalties.When dealing with utility patents, remember that theyprotect all forms of reproduction. Plants cannot bereproduced for research or for any reason includingusing saved seeds. The invention is the trait. Therefore,the utility patent covers any plant with that added trait(even if it is not labeled as such).A GREEN INDUSTRY GUIDE TO PLANT PATENTS AND OTHER INTELLECTUAL PROPERTY RIGHTS
What if ?I am growing plants with a disease resistancetrait that is covered by a utility patent next toa different variety of the same plant, if theseplants unintentionally cross pollinate and I plantthe resulting seeds from the unpatented variety,could I be liable for damages?Yes, plants with traits that are protected by utilitypatents cannot be used in breeding (or research).Although the breeding was unintentional, thisprotection still applies and you are infringing onthe utility patent.Utility Patent Case StudyIn Bowman v. Monsanto Company, a grower bought bulk soybeans from local grain elevators that he knewhad the Monsanto RoundUp Ready technology and used them as seed rather than as feed. This infringedon Monsanto’s patent. The grower argued that “first sale doctrine” (i.e., the buyer can do whatever theywant with a product after purchase) applied to these soybeans. His strategy was not successful. TheFederal Circuit Court ruled that the first sale doctrine does not apply to subsequent generations of selfreplicating technology.The main takeaway from this case is do not use a plant with a utility patent to produce seeds that you intendto grow into plants. Additionally, safeguard your nursery by buying utility-patented plants from the patentowner or a licensed seller, and do not take cuttings to produce more of the plant to sell.Plant Variety Protection (PVP) CertificatesThe Plant Variety Protection Act (PVPA) is a federal lawthat was established to protect the intellectual propertyof new sexually reproduced plants and tubers. Thisact was amended in 2019 to protect the intellectualproperty of new asexually produced plants as well. Tobe protected by the PVPA and eligible for a certificate,the plant variety has to be new, uniform (i.e., true totype), stable, and differ from the parent plants and otherplants resulting from cross pollination.A plant variety may be ineligible to receive a PVPcertificate if:1.madeavailableotherstheU.S.4. The varietyplant is aronebeforeyear beforeapplying,than oneapplying,2.5. The variety is made available to someone outside theU.S. more than four years from the filing date if it is ashrub, herbaceous perennial or annual, or3.6. The variety is made available outside the U.S. morethan six years after the filing date if it is a tree or vine.What if ?I cross pollinate a PVP-protected variety withanother variety and plant the resulting seed. Isthis allowed?This is a bit tricky. You are allowed to save seedand replant on your own property (but notsell the seed or other propagating material);HOWEVER, a PVP-protected variety cannotbe used to produce an F1 hybrid that will bemarketed as a new variety.PVP includes protections against the following acts:selling or marketing the protected variety; importing orexporting the plant from the U.S.; sexually or asexuallymultiplying the plant; using the variety to produce ahybrid; using a seed marked “Unauthorized PropagationProhibited”; and dispensing the variety to another in aform that could be propagated.A GREEN INDUSTRY GUIDE TO PLANT PATENTS AND OTHER INTELLECTUAL PROPERTY RIGHTS5
If any of the above actions are taken, it is consideredinfringement and can result in damages that theinfringer must pay.There are a few exceptions included in the PVPA law.The following are not acts of infringement:1. A farmer saving and replanting seed protected by aPVP certificate.2. A sale of seed produced on a farm for purposes otherthan reproduction (e.g., feed).3. Use in research.However, a PVP-protected plant cannot be used tomake an F1 hybrid that would be sold as a new variety.The plant would have to differ from the parentsand other offspring, such as from a mutation, to bemarketable as a new variety. The hybrid could be usedfor further breeding, but the resulting progeny must bedifferent from the hybrid and the PVP-protected plantin order to be marketed as a new variety. It is importantto note that the allowance of keeping seed andbreeding is different than with utility or plant patents.To summarize, if a plant is protected by PVP, you cannotsell or give away your seed, except as noted, or sexuallymultiply the plants for distribution. You are allowed tokeep seed year after year, but only for yourself. Theplants can be used in breeding experiments but can’tbe used as the parent of an F1 hybrid that is to bePVP-protected.TrademarksTrademarks are defined as, “any word, name, symbol,or device which a person has the intention to use incommerce and who applies to register the trademarkto identify and distinguish his or her goods.” Despitecommon misconception, trademarks identify thesource of a product rather than the specific productitself. Trademarks last 10 years but can be renewedindefinitely, and that is the reason they have becomewidely used by the Green Industry.Two main symbols are used to indicate trademarkstatus. The symbol means “Registered” and signifiesthat the trademark is registered with the U.S. Patentand Trademark Office and the rights are ownedexclusively. The TM symbol indicates that a word orgraphic is being claimed by a company or individual tosignify the source of their goods, but it has not beenfederally registered or that registration is still pending.An unregistered trademark gives very limited rights tothe company or individual. Companies or individualscan still sue for common-law infringement within theregion where the goods are produced and sold, but 6they must be able to prove they were the first to usethe trademark and that the infringing party’s use ofthe trademark confuses the public from distinguishingthe goods’ source. Varieties and cultivars are treatedidentically for trademark purposes and cannot betrademarked. In other words, cultivar names areconsidered generic. For example, if a new cultivar ofhydrangea is created and the name is Hydrangea ‘Joey’sJoy’, then the name Joey’s Joy cannot be trademarked.Additionally, once a name is established and used bythe general public it cannot be trademarked. Moreover,once a trademarked name becomes generally usedas the common or generic name for a product, thecompany risks losing their trademark. For example, both“escalator” and “trampoline” were once trademarkedbut are now recognized as generic names. Thetrademarked name must be unique and must havenever been used as a cultivar name or in connectionwith a plant patent, utility patent or certificate forplant variety protection. Descriptive names cannotbe trademarked. The best trademarks are namescompletely unrelated to the item (e.g., Kellogg’s ).Remember that a trademark should help informcustomers where a plant is from, not what the plant is.A good example of a properly used trademark isAmerican Beauties Native Plants . American BeautiesNative Plants is followed by the registered trademarksymbol on all plant labels to identify the source alongwith the common and scientific names. This is anappropriate way to use trademarks. Some growerstrademark a plant name and use it in conjunction withthe cultivar name as their name for that cultivar. Usingboth the trademarked name and the cultivar name ontags and in all advertising should help ensure that thetrademarked name is not recognized as the generic or , Does It Matter? Registered trademarkCan only be used for a trademark that has beenregistered with the USPTO. Using a registeredtrademark without permission is a federal offenseand could result in litigation.TM Unregistered trademarkFor use with trademarks that an individualor company does not intend to register andtrademarks for which registration is pending.Affords only slim common-law rights withina region.A GREEN INDUSTRY GUIDE TO PLANT PATENTS AND OTHER INTELLECTUAL PROPERTY RIGHTS
What Should You Do?A local college buys plants for a new building based on the lowest bid. When the order is delivered, thecampus grounds manager notices that plants she knows to be trademarked are not in branded containersand do not have the branding program’s label that is normally required with the sale of plants in thatprogram. What should she do?Even though these plants aren’t going into a retail environment and it takes time to remove labels at the jobsite prior to planting, all branded plants should be delivered with their respective containers and tags.The campus grounds manager should require that the seller provide these items or reject the plants.Contacting the license holder may be appropriate.name for the plant (Figure 3). This combinationon the tag should also help consumers identifythe source of the plant, but it doesn’t alwaysdo that. An example of this would be GertrudeJekyll rose. The scientific name is Rosa andthe cultivar name is ‘Ausbord’. Gertrude Jekyllfollowed by the registered trademark symbol issupposed to denote the source of the plant, butit is commonly called Gertrude Jekyll insteadof ‘Ausbord’. The trademarked name GertrudeJekyll does not help a customer recognize thatthe source is David Austin roses. Additionally,the name ‘Ausbord’, while listed online and onplant labels in conjunction with the trademarkname, is not widely recognized as the cultivarname for Gertrude Jekyll .NAME OF THE BRANDING PROGRAMIf you own a trademarked name, keep in mindit is supposed to state where a plant is from,not identify the plant. If you do not own atrademarked name, be sure you use the cultivarname and do not use others’ trademarkednames without a license agreement. Remember,anyone can sell under a cultivar name, as longas the plant is not patented, but you needpermission to use a trademarked name.When buying plants, it’s best to keep track of thecultivar name as well as the trademarked name,just like you would stay current on common andbrand names for pesticides because two sourcescould be selling the plant under two differentnames. For example, in 2008 when the patenton Rosa ‘Ausbord’ expired, David Austin rosescould continue selling the plant as the trademarkGertrude Jekyll while another company marketsit as ‘Ausbord’.SCIENTIFIC NAMETRADEMARKED NAMECULTIVAR NAMEPLANT PATENT NUMBERFigure 3. This label contains the cultivar and branded name on it, which should helpprevent the plant from becoming known generically by the trademarked name.A GREEN INDUSTRY GUIDE TO PLANT PATENTS AND OTHER INTELLECTUAL PROPERTY RIGHTS7
Trademark Case StudyProblems can arise when a plant becomes known generically by its trademarked name. An example in whichthis became an issue is the court case Van Well Nursery Inc. v. Mony Life Insurance Co., in which Mony LifeInsurance Co. advertised an apple cultivar, ‘Snipes’, by its trademarked name, Scarlet Spur . Van Well NurseryInc. sued the insurance company for trademark infringement, but the judge ruled that the cultivar was knownas its trademarked name in the public domain so the trademark was cancelled.This case study illustrates the delicate balance required to use trademarks to outlive plant patents. The GreenIndustry and their customers must come to associate the trademark with the cultivar name, but not to theextent that the plant becomes known generically by the trademark name.Comparing Different Types of Intellectual Property8Plant PatentsUtility PatentsPlant Variety ProtectionType of plant eligible forprotectionAsexually propagated plantsexcept for tubersAny type of plant trait(s)showing utilitySeed, tuber and asexuallypropagated plantsCan the plant be used forbreeding/research?YesNoYes, but F1 hybrid cannot bemarketed as new variety.Can the plant be reproducedsexually for distribution?Yes, not protected by currentpatent law.NoNoCan the plant be reproducedasexually for distribution?NoNoNoCan growers save seed?Yes, but risks infringementclaims if next generation issimilar to parent plants.NoYes, but cannot sell or giveaway; can only plant it ontheir land.Issuing agencyU.S. Patent and TrademarkOfficeU.S. Patent and TrademarkOfficeU.S. Plant Variety ProtectionOfficeLicensesRoyaltiesIn order to work with PVP-protected or patented plantsyou often need a license. The two types of licensesare distribution licenses or production licenses. Adistribution license typically doesn’t give the right topropagate or reproduce. If you buy liners and there’s alicense, you probably have a distribution license, whichmeans you can’t produce your own cuttings or liners.For that purpose you would need a production license.Production licenses can have extra details, such asexclusivity and territory, but these typically only applyin contracts to large propagation nurseries. Not everylicense will give all these rights, so be sure to read thelicense carefully.In order to legally grow plants that are patented orunder PVP certificates, the growers will pay up-frontfees, royalties on sale, or a combination of the two.Royalties are payments made to a patent owner forallowing a grower to produce or sell their plants. It’stypically a small cost but could quickly add up on largeorders. The royalty fee can roughly double the cost ofa hydrangea liner, substantially increasing productioncosts. Additionally, because the fees associated witha distribution license are paid up front, whether thecrop is ultimately sold or not, a crop failure or otherinterruption to sales could be more costly with apatented plant.A GREEN INDUSTRY GUIDE TO PLANT PATENTS AND OTHER INTELLECTUAL PROPERTY RIGHTS
ComplianceTo remain compliant with patent laws, growersneed to pay royalties, record sales and post patentnumbers on tags and in catalogs. Growers shouldalso take care to not reuse containers with patentedor trademark names on them for other plants (Figure4). Compliance inspectors visit nurseries and gardencenters in Tennessee every year to ensure these rulesare followed. Be sure you know the contents of andunderstand your license agreements. Consult with alegal professional if necessary.Open Source Seed InitiativeOpen Source Seed Initiative (OSSI) is an effort tosupport access to cultivars and plant genetics toanyone. It disallows patent or PVP protection and allowsall uses for free (i.e., planting, seed saving, developingnew cultivars). It is used when someone either doesn’twant to mass produce a new cultivar or wants toprevent others from doing so.Copyright ProtectionFederal copyright protection is for “original works ofauthorship fixed in any tangible medium of expression,now known or later developed, from which they can beperceived, reproduced, or otherwise communicated,either directly or with the aid of a machine or a device.”Copyright applies to a product as soon as the itemexists as a tangible medium (something that can beseen or heard) and lasts for the life of the author, plus70 years. It does not require any paperwork for it tobe active. In other words, you do not need to applyfor copyright protection; it automatically exists assoon as the work exists. Copyright protects authorsor publishers, if authors have assigned rights to apublisher, who fix an image of a plant or other subjectin a tangible medium (e.g., photograph or painting) byprotecting the “original work,” which is the image of theplant – not the plant itself. Generally, copyright is usedwith images, video and art.Exclusions to copyright include protection of an idea,process, system, principle and so on that is embodiedin the work. A good way to remember this is theFigure 4. Contact the patent or trademark holder about returningcontainers or recycle them. Do not reuse containers from brandingprograms. Photo credit: Grace Pietsch (bottom)image you created is protected, but not the objectof the picture or photo. For example, if you were tocreate a new technique for wrapping and pinningburlap around the root balls of field-grown trees andyou photographed the process, the images would beprotected by copyright, but not the burlapping processitself. Another exclusion to copyright is the “fair usedoctrine.” This doctrine allows for the reproduction ofthe copyrighted work without the consent of the authorand applies to criticism, comment, news reporting,teaching, scholarship and research.A GREEN INDUSTRY GUIDE TO PLANT PATENTS AND OTHER INTELLECTUAL PROPERTY RIGHTS9
AcknowledgementThis Extension publication was adapted from the Intellectual Property Module of the Advanced TennesseeMaster Nursery Producer Program created by Tammy Stackhouse, former Extension program assistant, andAmy Fulcher, associate professor and Extension specialist. Gratitude is expressed to Grace Pietsch for use ofher photograph and Matthew Chappell, Ryan Contraras and Bob Trigiano for their careful review of an earlierdraft of this publication.DisclaimerThe information in this publication is provided for educational purposes only. While the content of thispublication involves issues of a legal nature, it should not be relied upon as legal advice, nor should thisinformation be used as a substitute for the services provided by a qualified legal or other professional familiarwith your individual circumstances.Laws are subject to change and may have changed since this publication was prepared. Be sure to followcurrent local, state and federal laws regarding patent law and all other topics discussed in this publication.Always refer to a lawyer or qualified professional for proper application of the concepts in this publication toyour specific situation.References and Additional ReadingBrickell, C., C. Alexander, J. David, W. Hetterscheid, A. Leslie, V. Malécot, and J. Xiaobai. 2009. Internationalcode of nomenclature for cultivated plants. 8th ed.: International Society for Horticultural Science.Eisenschenk, C. 2016. Intellectual property protection for plants. In: Beyl, C. A. and Trigiano, R. N. (eds.) Plan
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