[2010] EWCA Civ 82 at [17]. That test is as follows: an invention shall be taken to involve an inventive step if it is 'not obvious' to 'a person skilled in the art', having regard to any matter which forms part of the 'state of the art' by virtue of section 2(2): s 3 Patents Act 1977. Courts of the United Kingdom have adopted a general framework to assist in approaching (not answering) the fundamental statutory test. It is known as the Windsurfing or Pozzoli test. In Windsurfing International Inc. v Tabur Marine (GB) Ltd. [1985] RPC 59 the Court of Appeal suggested the following framework: Identify the inventive concept embodied in the patent; Impute to a normally skilled but unimaginative addressee what was common general knowledge in the art at the priority date; Identify the differences (if any) between the matter cited and the alleged invention; and Decide whether those differences (viewed without any knowledge of the alleged invention) constituted steps which would have been 'obvious' to the skilled man, or whether they required any degree of invention. This test has been slightly reworked in the more recent Court of Appeal case Pozzoli Spa v BDMO SA & Anor [2007] EWCA Civ 588 (22 June 2007): (a) Identify the notional "person skilled in the art", (b) Identify the relevant common general knowledge of that person; Identify the inventive concept of the claim in question or if that cannot readily be done, construe it; Identify what, if any, differences exist between the matter cited as forming part of the "state of the art" and the inventive concept of the claim or the claim as construed; Viewed without any knowledge of the alleged invention as claimed, do those differences constitute steps which would have been obvious to the person skilled in the art or do they require any degree of invention? In Schlumberger Holdings Ltd versus Electromagnetic Geoservices AS [2010] EWCA Civ 819 (28 July 2010), the Court of Appeal clarified that the fictional skilled addressee (which may be a skilled team) used for determining inventive step can vary from the one used for determining claim construction or sufficiency. United States "Non-obviousness" is the term used in US patent law to describe one of the requirements that an invention must meet to qualify for patentability, codified in 35 U.S.C. §103 in 1952. One of the main requirements of patentability in the