Regardless of the options chosen, every developing country that may have any capability to engage in improvements of existing inventions and incremental innovation must be aware of the need to address so-called blocking patents, i.e. patents (which are typically foreign) that stand in the way of locally developed improvements. For this scenario, the TRIPS Agreement itself provides a solution in Article 31(1), which allows a compulsory license that enables the second comer to practice a patent on an improvement that might often infringe the dominant patent. Developing countries are free to adopt legislation enabling the issuance of compulsory licenses for dependent patents consistent with Article 31(1) of the TRIPS Agreement.