The software patent. International and national regulation.
The topic of software patents is proving to be a controversial and very interesting one in modern times, due to the intertwining of serious business interests with the rights of users and authors of software works that need protection. On the other hand, the problem refers to the existing purely legal collisions arising from the built contradiction between the European doctrine and the regime it advocates concerning the copyright regulation of software as a literary work (according to Article 10 of the Berne Convention - see 1971 version) in opposition to the Anglo-Saxon principled view that software can be a fit subject of industrial property, i.e. of patenting. The text of Article 10 of the "Berne Convention for the Protection of Literary and Artistic Works" expressly enshrines the rule that "computer programs, whether source or object, are protected as literary works under the Convention". A few years later, the World Intellectual Property Organization's Model Terms, published in 1978, reflected the definition of the phrase "computer program" as "a series of instructions that are embodied in a machine-readable medium so as to cause a machine having the capability of processing information to indicate, perform, and achieve a particular function, task, or result." This may also be considered to be the definition of the term 'software'.
We reach this conclusion because the title of the World Intellectual Property Organisation's 'Model Terms' is 'Protection of computer software'. This brief background leads me to the view that the international regulation of software patents has evolved in different countries of the world with different dynamics, with the concept of their legal regulation undergoing changes. These range from the original regulation of software as an existing eligible subject matter of first copyright and then patent law, to the contemporary - in my view highly exaggerated - thesis that software as an achievement of the creative industries and science should not be "monopolized" by business through patents, but should become one of the free and unpaid achievements of society.
1.The software patent in the Anglo-Saxon patent system.
1.1.UK patent law is at present fully compliant with the meaning of the 'European Patent Convention', in which sense computer programs are outside the scope of patentability requirements. However, English case law takes the position that an alleged invention can only be considered a patent if it provides a real contribution which is technical in nature. Therefore, a computer program relating to business process concepts cannot be registered as an invention, but a computer program for carrying out an industrial process may be patent eligible subject matter. An example of the above is the historical fact that on 21 May 1962, a software patent application was filed in England by the British Petroleum Company entitled "A Computer Arranged for the Automatic Solution of Linear Programming Problems". The invention is concerned with the efficient management of computer memory, directed to the creation of simple mathematical algorithms, which as a result are implemented by purely software means. Linear programming, or linear optimization, is a method of achieving the best economic result at maximum profit and minimum cost, which is a mathematical model represented by linear relationships. In the present, linear programming is used in transportation, energy, telecommunications and design. In the particular case commented on, the English software patent for linear programming relates to an optimised process for creating an algorithm for fast data transmission. The patent was registered on 17 August 1966 (available on the website of the European Patent Office as Abstract No GB1039141) and is considered to be one of the first software patents in the world. In Australia, which is also an Anglo-Saxon patent system country, purely abstract methods of doing business are not considered patentable, but if the method is carried out using a computer then it is an exception to the general rule and the invention is patentable.
1.2.The Canadian case law relates to two main cases which illustrate the great importance of certain criteria determining the patentability of inventions involving computer software. The first relates to a 1981 case in which the Federal Court of Canada considered the patentability of an invention involving software in the Schlumberger case. The appellant, whose software patent had been opened for registration by the Canadian Patent Office, appealed the refusal, seeking to patent a method for analyzing measurements from oil and gas exploration wells. The application of the invention relates to a process in which measurements are processed by a computer for mathematical analysis. The court stated in the reasons for judgment that the calculations involved in the invention( if they were done by a human) were " mathematical formulae and a number of purely mental operations". The court also found that mathematical formulas are not patentable under Canada's "Patent Act", and this also applies to scientific principles or abstract theorems. The Federal Court of Canada reasoned its decision by noting that "the fact that a computer is used to carry out a discovery does not change the nature of that discovery." In this context, the appeal in Schlumberger was dismissed, and accordingly the software work was found to be unpatentable, as the use of a computer in the described hypothetical does not help either to patent the commented method or to designate it as alleged subject matter. In 2011, the Canadian Federal Court considered for the second time the question of the patentability of an invention using software in the Amazon.com case. The Amazon plaintiffs, who have been denied registration of a software patent by the Canadian Patent Office, seek to patent a "one-click" method of making online purchases that would allow a user to make an online purchase without the requirement to re-enter for billing and shipping. The Federal Court remanded the case to the Canada Patent Office for reconsideration on the basis that the decision to reject the patent, and in particular the finding that the subject matter of the patent claims was unpatentable, was incorrect and the patent should be treated as having patentable subject matter. Judge Fallon, who heard the case, based his decision on the view that the patent claims wholly comprised the five requirements of patentability that exist in the Canadian "Patent Act", with the disclosed invention relating to a "machine" that was patentable subject matter. Based on this dispute, Amazon's patent was registered in December 2011. This interesting case has also led to a change in Canadian patent law regarding options for software patent registration. On March 8, 2013, the Canadian Patent Office announced changes in practice regarding patent examination based on the Amazon decision. The Office published new guidelines for determining an invention as patentable based on purposeful claim construction relating to a software patent, referred to as CII(from Computer-Implemented Inventions) for short. In the Canadian Patent Office's Examination Guide for Patent Applications, the CII is used as a basis for the examination of patent applications. Manual of Patent Office Practice (MOPOP) and its Article 16 expressly enshrines the rule that software incorporated into an invention may be claimed solely and exclusively as a method (article, process or method of manufacture) or as part of a machine (usually a device that operates by means of a computer), and/or product (article of manufacture). The MOPOP Guide also provides that no software work may be claimed as a patent where it is a computer program, database or computer generated signals.
1.3.US software patent case law.
The U.S. Patent Office has registered inventions that qualify as software patents since the early 1970s. Statistics show that since 1985, when an average of 2,000 software patents were registered per year, by the year 2000 the number of software patents had increased nearly 10-fold, with nearly 18,000 software patents being registered annually since the beginning of the millennium. One of the earliest cases in US jurisprudence involving software patents was Gotschalk v. Benson. Gottschalk v. Benson - 409 U.S. 63 (1972). The case concerned a legal dispute over the filing of an application with the U.S. Patent Office for an invention that related to the processing of program data and, in particular, its conversion into numerical information for personal computers. In detail, the patent application claims a method for converting signals from an encoded binary form into a pure binary code of zeros and ones. Appellants appeal the U.S. Patent Office's refusal to register the patent on the ground that, under Section 35 of the U.S. Patent Act, conventional programs for general use in computers that are a series of mathematical sums or psychological steps (see Patent Act, 35 U.S.C. § 100(b). Pp. 409 U. S. 64-73). The U.S. Supreme Court issued a decision rejecting the patent, reasoning that a process patent cannot be registered, especially "if it is based on mathematical formulas and its practical effect would be a patent on the algorithm itself." In 1981. In 1981, the US Supreme Court reinterpreted Article 35 of the US Patent Act in a case involving a software patent in Diamond v. Dier. Diamond v. Diehr, 450 U.S. 175 (1981). The patent application at issue in this litigation concerns an invention applied for registration for molding and maturing raw, synthetic rubber. The process uses a mold to accurately form and mature the material under heat and pressure, followed by curing the synthetic rubber in the mold so that the product retains its shape and is functionally operable after the process is completed. The complainants submit that their process ensures the production of moulded products which are properly cured. Achieving the ideal cure depends on several factors, including the thickness of the article when molded, the temperature of the injection molding process, and the amount of time the article is allowed to sit in the press. The best combination of time, temperature and cure, which is important for press opening, is calculated based on Svante Arenius' equation (Swedish physical chemist, Nobel Prize winner in chemistry, creator of the theory of electrolytic dissociation). The appellants point to the innovation of the patent applied for by their contribution to continuously monitor and measure the temperature inside the mould. These temperature measurements are carried out automatically by a computer which repeatedly recalculates the curing time according to the Arrhenius equation. The examiner at the USPTO rejected the applicants' patent claims on the sole ground that they were unlawful under Article 35 of the US Patent Act, since the steps described in the claims were performed by means of a computer under the control of a stored program, citing the precedent of Gotschalk v. Benson. Gottschalk v. Benson, 409 U.S. 63 (1972). All of this leads the Examiner to conclude that appellants seek protection of a computer program for a forming press by their patent claims. On appeal, the Supreme Court concluded that appellants' claims were not directed to the protection of a mathematical algorithm or method of calculation, but rather to a method of molding rubber articles by solving a practical problem that arose in connection with the molding and curing of rubber articles. Therefore, the court ruled that "patent claims cannot be unlawful simply because they contain a mathematical formula, a computer program, or a numerical code," but rather, they are patentable if they are applied to a structure or process that can be viewed in its entirety as technically practicable, i.e., they perform a technical function that the patent laws view as subject matter protection. In connection with the different treatment of patent rights in different parts of the country.
In 1982 the US Congress created a new specialized court - the Federal Court of Appeals. United States Court of Appeals for the Federal Circuit, abbreviated CAFC) to hear patent cases. Following several landmark decisions of this court, in the early 1990s US case law definitively established the patentability of software patents, and in 1996 the USPTO adopted the so-called Final Computer Related Examination Guidelines. This document advocates the rule that "applications for software-related inventions are subject to mandatory examination. This requirement should be distinguished from the differently worded prohibitions against patenting abstract ideas, laws of nature or phenomena", which exist both in the US legislation and in other national and international acts (including the Bulgarian Patent and Utility Model Registration Act - Article 6, paragraph 2, item 1). The recent growth of the Internet and e-commerce has led to the application and registration of numerous patents in the US that relate to business models (methods) implemented in software, with the caveat that whether business models are patentable is a different theoretical and practical question than whether software is patentable. For many years, the USPTO maintained the position that methods of doing business or business models are not patentable. With the increase in patent applications concerning the Internet or e-commerce methods in the 1980s and 1990s, the USPTO established a firm practice advocating the rule that it is not practicable to determine which invention is a technical one or a business method. In this line of reasoning, examiners were obliged not to consider an claimed invention as a method of doing business (regardless of whether the application contained such claims), but rather to be guided by whether the general substantive requirements that would be important de jure to the patentability of any invention in general were present.
2.The software patent in the European patent system.
The patentability of software, computer program and/or computer-implemented inventions within the European Patent Convention (EPC) is the legal option according to which the said objects would be registered under the said international act on the grant of European patents adopted on 5 October 1973. This criterion (patentability) also includes the objective assessment of whether European patents granted by the European Patent Office (EPO) in the specific fields referred to, conventionally referred to as 'software patents', are considered valid by national patent offices and courts respectively, as eligible subject matter of patent law. It should be noted here that the Munich, Germany-based "Foundation for a Free Information Infrastructure" (FFII), which at the turn of the century was actively fighting the so-called "software patent trolls" in Europe, had defined a software patent on the grounds that it should not be allowed as an existing subject matter of patent law, defining it as "a patent for any kind of computer representation made by means of a computer program". In 2005, the European Patent Office defined a software patent as an invention directed to the protection of a computer program declared to be a taxonomy per se or an algorithm or a computer-applied business method that has no technical contribution. This definition concerned the EPO's intention to adopt a so-called "Directive on the patentability of software products". After nearly three years of debate on the subject, the European Parliament unanimously rejected the adoption of the Directive on the grounds that its legislative establishment would have allowed the patenting of computer-implemented inventions, i.e. inventions achieved by using a computer, a computer network or similar equipment, which would at least have been contrary to international practice and, in particular, to the Berne Convention. It is correct to point out that under the EPC, and specifically Article 52 thereof, "computer programs" are not recognised as inventions that would be protected as European patents. This exception from patentability only applies to cases where the European patent application relates solely to a computer program per se. In relation to the rule of Article 52 EPC, applications which concern "software patents" are subject to an extremely strict examination compared to that which, for example, is carried out in the US in respect of the same subject matter, but this does not at all mean that within the European Patent Office all inventions which concern or contain software are de jure unpatentable. The European Patent Convention advocates the rule that a European patent can protect inventions in all fields of technology which are novel, have an inventive step and would be successfully industrially applicable (Article 51(1) EPC).
By contrast, Article 52(2) EPC excludes from patentability the following subject-matter: -discoveries, scientific theories and mathematical methods ; -aesthetic creations ; -plans, rules and methods of intellectual activity, video games or rules of business activity (business methods) and computer programs; The provisions of the second paragraph on non-patentability apply only to the extent that the European patent application or European patent relates to the subject-matter referred to in the text in question per se. Confirmation of what has been said is the fact that the firm practice of the Boards of Appeal of the EPO , indicates the reasoning that an invention is patentable if it offers a new and non-obvious technical solution to a technical problem. provides a new and non-obvious " technical " solution to a technical problem. Alternatively, the technical problem to be solved may also focus on the problem of how to make the computer itself easier to use(assuming that it is also part of the prior art). An example of practice in this respect is Decision No. T928/03 rendered by the Board of Appeal of the European Patent Office on 2 June 2006 in relation to Application No. 97120468.0, with the applicant being KONAMI CO., LTD. The proposed patent makes it possible to display an indicator(an interface that assists the player with certain information - for example, errors made) on the user's screen of an interactive video game, which technical result is not mediated by a psychological process in the human brain, but is instead related to the display of a specific technical function on the screen. The functionality of the invention is not vitiated by the fact that the visualized information also comes into the user's use by interacting with the video game displayed on the screen.
The practice in relation to software patents applied for or registered in Europe contrasts with that of other countries in the Anglo-Saxon system, such as the US and Australia. In these countries, the mere use of a computer is sufficient to render a business method patentable, even if the computer is not used in a new or inventive way, but merely mediates or technically provides the business method which has patentable characteristics. Such a position has been explicitly rejected by the EPO in deciding on the patentability of software patents, an example in this respect being Case No. T258/03, decided by the Board of Appeal of the European Patent Office on 21 April 2004, in relation to application No. 97306722.6, with the applicant company HITACHI, LTD. In that case, the Board of Appeal of the EPO held that a methodology consisting of modifications to business models aimed at circumventing a technical problem rather than solving it by technical means did not contribute to the patentability of the claimed invention. This case concerns a computer program that connects several computer devices in a network in order to conduct an auction for a product. In view of the fact that the claimed invention does not offer a new technical solution and fully fulfils the norm of Article 52(2), third sentence of the EPC, it was rejected as unpatentable by the Board of Appeal of the EPO. 2.1 Case law on software patents at the European Patent Office. The EPO case law has been fairly consistent in its treatment of the various elements of the factual constitution of Article 52(2) EPC. For example, mathematical methods are firmly excluded from patentability, but an electrical filter designed in accordance with such methods will be registered as a patent if it meets the requirements of Article 52(1) EPC. In relation to the hypothesis of Article 52(2) EPC, computer programs are patentable to the extent that they provide a technical solution which contributes to enriching the state of the art.
In accordance with the practice of the Boards of Appeal of the EPO, "technical contribution" usually means a future technical effect that goes beyond the normal physical interaction between a program and a computer. The EPO Boards of Appeal have also accepted the motive that a technical effect provided by a computer program may be, for example, reduced memory access time , better control of a robotic arm, or improved reception and/or decoding of a radio signal. An important point is that this effect does not have to be external to the computer from which the program is executed - for example, increasing the impact of the interface on the user or optimising the access time to the hard disk may qualify as technical effects that would render a software patent application patentable. As of 2013, the fundamental substantive criterion used to distinguish patentable inventions from non-patentable inventions is that the subject matter of the application has technical applicability. Whether the invention in question has "technical character" (as in fact the original English translation is "technical character") is assessed by the examiner without taking into account the prior art, i.e. the so-called "technical contribution" (which criterion concerns novelty but not technical applicability). This reasoning leads to the conclusion that whether an invention is technically applicable has nothing to do with whether the same invention contributes to the state of the art. Stefan Steinbrenner (former President of the Boards of Appeal of the EPO) takes the view that any subject matter listed in the hypothesis of Article 52(2) EPC - including computer programs - may form part of an invention applied for if the latter has technical applicability or contributes to it (in particular, a technical problem is solved by the use of technical means or a technical effect is achieved; technical synergies are created or technical applications are achieved, in other words - the subject matter is demonstrably technically usable).
In fact, around 1996 there was a change in the EPO's practice as to which invention has a "technical effect" or applicability, according to the norm of Art. 1 and 2 of the EPC. Under the "inventive step" test (see EPO Decision No. T 52/85), the subject matter claimed does not constitute an invention within the meaning of Article 52(1) EPC where no technical contribution has been made relating to a field which is patentable. A seminal decision on the interpretation of Article 51(1) and (2) EPC is that in Case No. T 258/03 concerning the application of Hitachi for a method of conducting tenders. The commented decision of the Board of Appeal of the European Patent Office (EPO) was handed down on 21 April 2004 and it concerns to a considerable extent the assessment of the technical character of an invention and its inventive step. The reasoning of the decision states that 'a method which involves technical means is an invention within the meaning of Article 52(1) EPC. Decision No. T 258/03 contrasts with a slightly older decision of the Board of Appeal of the EPO No. T 931/95 concerning the application of the Pension Benefit Systems Partnership. The latter enshrined the rule that 'the mere fact that the processing of a database is carried out by means of computational means, i.e. technical means, does not necessarily determine the fact that the claims set out grounds for the technical nature of the method claimed for registration'. I am trying to explain that, in fact, decision No. T 258/03 puts apparatus patents (relating to software) and methods (relating to or mediated by software) on equal footing with respect to patentability examination under Article 52(2) EPC. In other words, the Board of Appeal of the EPO introduces new grounds of examination by this decision, specifying that the term "invention" in the definition of patentable inventions contained in Article 52(1) EPC is to be interpreted as "subject matter of a technical nature". Thus, the presence of hardware in the asserted patent claims, which concern a business method providing the realisation of a technical result, will be sufficient grounds to overcome any objections of the examiner as to the patentability of the business method, in particular the likelihood of its technical contribution. Decisions such as No. T 258/03 have made it clear that the "technical contribution" criterion is no longer really applicable. However, it should be noted that not all methods involving the use of technical means are patentable. They still have to satisfy the substantive absolute grounds for patentability, namely that they are novel, constitute a non-obvious technical solution to a technical problem and are industrially applicable. The expertise concerning the hypothesis of Article 52(2) and (3) EPC is only the first element of the complex factual composition of patentability as a substantive criterion. Computer programs applied for as software patents are often also rejected for lack of the second element of the factual composition - an inventive step. The first and the second element may not be in perfect combination, i.e. the presence of only one of the two elements leads to lack of patentability, in view of which it should be noted once again that, according to the modern practice of the Boards of Appeal of the EPO, it does not really matter for patentability whether an invention has a "technical contribution" or not.
The interpretation made by the Boards of Appeal of the EPO of the term "invention" concerning the definition relating to patentable subject matter was necessitated by an adjustment in the case law in relation to the element of "inventive step". This change concerns Case No T641/00, which was motivated by the conclusion that an invention may consist of a combination of technical and non-technical features. In such cases, the EPO usually applies the so-called "Comvik approach" to assess whether the invention has an "inventive step". Any non-technical function, i.e. one in a field excluded from patentability under Article 52(2) and (3) EPC, cannot be taken into account in the examination concerning the "inventive step" criterion unless it interacts with technical subject matter (the subject matter of the patent application) which is directed to the solution of a technical problem. In this context is also the decision No. T0154/04, which was rendered by the Board of Appeal of the EPO on 15 November 2006. in patent application No. 94912949.8 of DUNS LICENSING ASSOCIATES, L.P.. The reasoning of this decision advocates the rule that business research methods are excluded "as such" from patentability under Article 52(2) and (3) EPC. The Board of Appeal also held that the collection and evaluation of a database as part of a business research method does not convey the technical character of the claimed method if that process does not contribute to the solution of a technical problem. The reasoning of the decision also laid down the normative rule that, in relation to the hypothesis of Article 52(1) EPC, in order for an invention to be considered patentable, it must meet the requirements of novelty, inventive step and industrial applicability. As regards the concept of "state of the art", which has been used in theory as a starting point for the assessment of the inventive step, it should be said that it is interpreted in the sense of "prior art", but from the point of view of the person skilled in a particular field of technology (e.g. a software engineer or developer). The objectives of the examination thus carried out are how far a technical problem can be solved by the relevant technical specialist, at the priority date of the patent application. In this context, when it comes to a software patent, an expert in marketing or insurance policies cannot be chosen instead of an expert in computer hardware or computer memory management. This means that the mere implementation of a business method by a computer or computer network rarely involves an inventive step unless that process results in a computer-assisted and significantly improved industrial outcome or the computer is used to more efficiently manage the computer memory itself. Here again, we return to the view that an inventive step will only be present where the software patent is not such per se, but is industrially applicable. Interestingly, the case law of the EPO Boards of Appeal is not binding on the EPO Divisions of First Instance (i.e., the Divisions conducting the examination), and they reserve the right to assess patentability in the manner that suits them. In my view, this intra-departmental structure of enforcement is paradoxical and risks subjectivism and non-application of the seriously reasoned and thoroughly researched normative basis relating to the EPC that has become a constant practice of the Boards of Appeal.
The other specific point is that on the basis of Article 99 of the EPC, any third party (natural or legal) may file an opposition to the patent on the following grounds within nine months of the publication of the notice of grant of the European patent in the European Patent Bulletin: -the subject matter of the European patent is not patentable within the meaning of Articles 52 to 57; -the European patent does not disclose the invention in a manner sufficiently clear and complete to enable it to be carried out by a person skilled in the art; -the subject matter of the European patent goes beyond the scope of the application as originally filed or, if the patent is granted for a divisional application or for a new application filed under Article 61, beyond the contents of the earlier application as originally filed. The peculiarity here is that the opposition procedure before the EPO may have two outcomes (cf. Decision No. T2427/09, concerning the software patent applied for by NEOMEDIA concerning remote access to internet resources). In the first case, if the "Opposition Division" considers that there is at least one proven ground which appears to be an obstacle to maintaining the European patent, it declares the patent invalid or, otherwise, rejects the opposition as unfounded (Article 101(2) EPC). In the second option, if the "Opposition Division" considers that, due to the amendments made by the patent proprietor during the opposition proceedings, the patent and the invention to which it relates meet the requirements of the EPC, it is decided to maintain the patent as amended. If, on the other hand, the Opposition Division finds that the amendments made in the opposition proceedings do not comply with the substantive requirements of the EPC, the patent shall be declared invalid (Article 101(3) EPC).
3.The software patent in the Bulgarian patent system.
The principle opinion advocated by the Bulgarian legislation and in particular by Article 6(2)(3) of the Law on Patents and Registration of Utility Models is that "plans, rules and methods for intellectual activity, for games or for business activity and computer programs are not patentable. As in international practice, an exception to this rule is expressly provided for, by providing that Article 6(2)(3) of the MIPPA applies only where protection is sought only in respect of the objects referred to per se. This means that if they are implemented in or contribute to the technical result of inventions applied for registration, which are new, have an inventive step and are industrially applicable, then one can speak of a so-called software patent (Art. 6(3) of the RPML). An example in this respect are some medical devices(but not methods - see the prohibition of Art.7(1) of the MDRIPA) whose technical result(e.g. a pacemaker or an orthopaedic robot for drilling joints with a computer terminal) is facilitated as operation by software and/or hardware that transmits information about how it works, i.e. what is the specific technical result of the operation of the technical device itself in the human body. Such a patented device is the robot "DORO". It is an orthopaedic robot for automatic drilling, and its power and electronic units, computer terminals, executive mechanical module, etc. are included in the claims. The technical application of this robot is controlled by its control unit. It consists of a main power supply module, motor power supply units, power modules for the controllers, and the controllers themselves. It also houses the terminals for connections to a computer. The latter provides the ability to reprogram and program the robot itself, allowing real-time bone drilling. For the invention in question, utility model No. 1053/24.07.2008 and invention patent No. 66136/17.08.2011 have been registered with the Patent Office of the Republic of Bulgaria.
A particularly interesting Bulgarian invention in the field of so-called "software patents" is also, in my opinion, patent No. 63704/04.10.2002, under the name "Digital writing and communication method in native language". The invention (with the author engineer Koicho Mitev) presents a method for phonetic structural analysis of human speech, thanks to the use of the digits of the decimal number system all world languages and dialects are reproduced. Words from each language are entered into a computer, which mediates the process of their reproduction in conversation (for example, in a conference call you speak in Bulgarian, and the other party receives the conversation in Chinese). Given the fact that the sector of the Bulgarian economy that deals with the creation of software products is the most dynamically developing and stable market segment, in which significant capital has been invested, I cannot explain the lack of growth of patents that can be qualified as "software" naturally under the provisos expressed in this statement. There is also a real lack of jurisprudence in Bulgaria on the issue of "software patents", which would provide a detailed regulation of this modern topic in patent law, with the aim of better enforcement, stabilization of business and economic initiative, all of which confirms the conclusion of low patent activity. I hope that this article has given the right guidance to business and has led to the view that software patents are possible in Europe as well as in Bulgaria, but with well-defined characteristics of the desired subject matter of patent protection.
Author: Mr.Atanas Kostov – attorney at law