to prevent the abuses which might result from the exercise of the exclusive rights conferred by the patent, for example, failure to work. (See also Article 5A.(3) to (5) of the Paris Convention.) According to historian Adrian Johns, the idea of compulsory licensing "seems to have originated as a serious proposition in the 1830s, although predecessors can be traced back into the eighteenth century," and it was popular in the British anti-patent movement of the 1850s and 1860s. More recently an area of fierce debate has been that of drugs for treating serious diseases such as malaria, HIV and AIDS. Such drugs are widely available in the western world and would help to manage the epidemic of these diseases in developing countries. However, such drugs are too expensive for developing countries and generally protected by patents. United States In the United States, if the federal government or one of its contractors infringes a patent, the only remedy available to patent holders is a lawsuit in the Court of Federal Claims. It is the policy of the U.S. Department of Defense to allow contractors to infringe patents and to defend the contractor against patent infringement claims at government expense. Use of this provision by agencies other than Department of Defense is rare. During the 2001 anthrax attacks through the US Postal Service, the US government threatened to issue a compulsory license for the antibiotic drug ciprofloxacin, if the patent owner, Bayer, didn't lower the price to the government. Bayer lowered the price and the government backed down on the threat. India In India, compulsory license may be issued by the Controller General of Patents, Designs and Trade Marks under section 84(1) of The Patents Act, 1970, if: The reasonable requirements of the public with respect to the patented invention have not been satisfied, or, the patented invention is not available to the public at a reasonably affordable price, or, the patented invention is not worked in the territory of India. In March 2012, India granted its first compulsory license ever to Indian generic drug manufacturer Natco Pharma for Sorafenib tosylate, a cancer drug patented by Bayer. Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPs) The Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPs) also sets out specific provisions that shall be followed if a compulsory license is issued, and the requirements of such licenses. All significant patent systems comply