The study of patenting trends in the five countries confirms a significant proliferation of patents on developments of incremental nature and, in many cases, of questionable inventive step. This is well illustrated by the case of India where despite the patentability exclusions provided in section 3 of the Patent Act, a significant number of patents have been granted for possibly non-allowable claims. A total of 688 patents of this kind were identified, including claims on compositions (414) and formulations (137) which only in very exceptional cases would satisfy a rigorous examination of inventive step (Correa, 2006).