Patent Protection System for Computer Programs in Indonesia and Its Comparison with Several Countries: What's the Issue?

This paper attempts to examine patent protection systems for computer programs in several countries. During this time, computer programs were known as objects of copyright protection systems. But in reality, computer programs have become objects of patent protection systems (Article 27 (1) TRIPs Agreement). On this basis, it is interesting to study the history of patent protection systems, patent protection systems for computer programs internationally and their arrangements in Indonesia and some countries. The results show that there are similarities and differences in patent protection systems in Indonesia, Japan, the United States, and China. Factors cause this equation| (1) the basis of international law which is used as the same reference, which refers to Article 27 (1) TRIPs Agreement, in which the four countries are members of the WTO/TRIPs Agreement| (2). National interests of each state related to the importance of patent protection on computer programs, all of which assume that the patent protection system is needed in protecting computer programs produced by the community. Factors cause the difference| (1) ways to formulate laws that are different from the four countries, (2) experiences from these countries, and (3) national interests in implementing patent protection strategies on different computer programs.