An alternative view, however, favoured by the United States and the Australian Law Commission, is to hold that patent incentives to medical treatments are too important to exclude them from eligibility. Instead, while broadly allowing the patentability of medical tools and techniques to encourage investment in R&D, the United States has adopted a narrow exception to shield medical practitioners (and, for example, the hospital employing them) from patent infringement when carrying out “pure medical methods”. Integra sued Merck for patent infringement.