ELI LILLY AND COMPANY 
INDIANAPOLIS, INDIANA 40100 
C. W. PETTINGA 
EXECUTIVE VICE PRESIDENT 
September 30 , 1976 
Donald S. Fredrickson, M.D. 
Director, National Institutes of Health 
Department of Health, Education, 
and Welfare 
Bethesda, Maryland 20014 
Dear Dr. Fredrickson: 
We appreciate your courtesy in asking for our comments on 
patent policy in the area of recombinant DNA research 
activity. The background information which your letter 
provided substantially assisted in our appraisal of this 
situation and in the development of our views. We have 
carefully considered the points in your letter and have 
the following comments. 
Stanford University and the University of California 
Patent Applications for the Process of Forming 
Recombinant DNA and the Appropriate Administration 
by NIH of Patent Activity in this Area: 
Assuming these applications described patentable 
inventions, we feel that the patents should issue 
to the universities as would any other patent 
under an Institutional Patent Agreement. In our 
view, the IPA program as administered by HEW has 
fostered and encouraged productive research and 
has well served the public interest. 
Although the scope of coverage of patents for 
inventions in the recombinant DNA field is 
potentially broad, we do not feel that NIH should 
substantially modify its basic policies as con- 
tained in the IPA program for inventions in this 
area. The IPA program has encouraged the develop- 
ment of new technology and has provided incentives 
for industry to invest not only in research but 
in production facilities to bring the products of 
such research to the public. 
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