"manufacture" or "composition of matter". The majority noted that while these words indicated that Congress intended for the patent laws to be given a "broad scope", this scope was not unlimited and that, under the Court's precedents, "laws of nature, physical phenomena, and abstract ideas" were not patentable. However, the Court held that these precedents were inapplicable to Chakrabarty's case as he was not trying to patent a "natural phenomena" but rather a human-made bacterium that he, himself, had developed. The majority contrasted this outcome with the one reached nearly 50 years prior in Funk Bros. Seed Co. v. Kalo Inoculant Co., where the Court had rejected a patent application for the discovery of a naturally occurring bacterium that could be used to improve crops. Unlike the patentee in Funk Bros., the Supreme Court here held that Chakrabarty had not merely discovered the bacteria's existence, he had created it himself and adapted it to a particular purpose. Justice William J. Brennan Jr., joined by Justices Byron White, Thurgood Marshall, and Lewis F. Powell Jr., dissented from the Court's ruling. Looking at the legislative history of the patent laws, Justice Brennan concluded that Congress had demonstrated an intent to exclude living organisms from the scope of the country's patent laws. Justice Brennan also expressed concern that the Court was extending patent protections into areas not expressly authorized by Congress and that this constituted an inappropriate extension of monopoly patent power. Impact In the decades following the Supreme Court's ruling, commentators have classified Diamond v. Chakrabarty as an important legal decision, particularly with respect to the patent laws and the biotechnology industry. In 2018, Time identified the decision as one of 25 important moments in American history, with Professor Gerardo Con Diaz remarking that the decision allowed "inventors at private and public institutions alike to obtain patents for genetically modified organisms — from plants and animals for laboratory research, to many foods available in supermarkets today" and allowed biotechnology firms to protect their developments in new ways. Writing for IP Watchdog on the decision's 30th anniversary, Gene Quinn called the decision a "turning point for the biotech industry" and praised the Court's ruling as "emblematic of the need for an expansive view of what is patentable subject matter." Likewise, the Biotechnology Innovation Organization praised the decision as being "instrumental in spurring the creation of a dynamic and flourishing biotech industry." Nature similarly