on a higher life form. Two years later, in Monsanto Canada Inc. v. Schmeiser, an equally narrow majority of the Supreme Court found that a farmer, by knowingly growing a crop containing genetically modified genes and cells that was not purchased, had infringed Monsanto's patent. Schmeiser, the farmer, argued that, per Harvard College v. Canada (Commissioner of Patents), higher life forms, such as plants, do not constitute patentable subject matter in Canada, even though Monsanto's patent was only directed to the modified gene and the cells containing the gene. This argument was rejected by a majority of the Court, which found that “[w]hether or not patent protection for the gene and the cell extends to activities involving the plant is not relevant to the patent’s validity”, and since Monsanto did not claim a patent for a genetically modified plant per se, its claim of the gene and the cell was considered patentable subject matter. The distinction drawn in Harvard between higher and lower life forms has been criticized as one that is difficult to draw and has no logical basis. However, after Monsanto Canada Inc. v. Schmeiser, this distinction may not even matter anymore because even though, per Harvard College v. Canada (Commissioner of Patents), higher life forms such as plants or animals are not patentable, Monsanto Canada Inc. v. Schmeiser has nonetheless given patent protection to these higher life forms by allowing protection for the modified genes and cells that compose the plant or animal. Business methods: Amazon's one-click shopping patent In 1998, Amazon.com filed a patent application for a “Method and System For Placing A Purchase Order Via A Communication Network”. This invention allowed customers shopping online to make purchases with one-click buying, which circumvents the process of entering address and billing information in the traditional shopping cart mode of online shopping. The Commissioner of Patents rejected the patent finding that the substance of the claims were directed to a "business method". The Commissioner argued "business methods" were excluded as patentable subject matter. Amazon.com appealed the matter to the Federal Court. The Federal Court rejected the Commissioner's characterization of "business methods" as an excluded category of subject matter. The court found that instead the patent's claims should be assessed against the five categories of statutory subject matter found in the Patent Act. Justice Phelan held that purposive construction of the claims clearly disclosed a "machine" and thus were