1. Which the Appeal Board had held to be a narrower taxonomic class than a species. The claim was to all no-human mammals that had been genetically modified to contain certain genes and so clearly did not fall within this definition of "variety".

2. Decision of 8 December 1994 by the Opposition Division [1995] OJ EPO 388.

3. Hybrid Plants/Lubrizol T 320/87 [1990] OJ EPO 71

4. Case T 356/93 [1995] OJ EPO 545.

5. Case G3/95 [1996] OJ EPO 169.