While subsequent case law in the area of gene patents seems to have abandoned the teaching, suggestion, and motivation test,198 the CAFC has continued applying that test in the context of small molecule patents.199 Whatever the final outcome in the United States, developing country authorities concerned with the granting of new patents for trivial improvements to existing inventions, such as combining one drug with another, should consider building upon the United States Supreme Court’s KSR decision in the context of their own laws, regulations and examining procedures. The new approach may reduce the number of trivial or dubious patents, especially in the information technology and pharmaceutical industries. Policymakers interested in special protection outside of the patent system for small-scale innovations within the reach of local entrepreneurs may wish to consider these alternatives. In practice, courts and administrators in developed countries often supplement these factors by so-called “additional” or “secondary”, objective factors (i.e. related to the invention) bearing on non-obviousness.