The first U.S. patent law, passed in 1790, protected the invention of "any useful art, manufacture, engine, machine or device, or any improvement thereon not before known or used." But are items of manufacture necessarily inanimate? Apparently not. In 1930, Congress voted to approve the patenting of new plants produced by grafts, cuttings or other asexual methods. Half a century later the Supreme Court went even further and ruled that the law would apply to genetically engineered micro-organisms, such as a new strain of bacteria designed to gobble up oil spills. In the view of the court, "anything under the sun...
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