This approach has been widely tested in practice. For example, Germany and Japan, which introduced pharmaceutical product patents in 1968 and 1976, respectively, successfully used their utility model laws to protect small-scale innovation for decades.156 The Japanese utility model law, which once witnessed close to some 200,000 applications a year,157 allowed Japanese inventors to protect small-scale improvements of foreign inventions. Indeed, these local innovators often “surrounded” the foreign invention to the point where negotiated cross-licensing became necessary. Utility models (“petty patents”), for which the TRIPS Agreement does not provide any binding minimum standards, are usually granted for small-scale inventions that do not meet the eligibility standards under patent law, especially the inventive step requirement.