On June 25, 2004, the U.S. Senate passed the Cooperative Research and Technology Enhancement (CREATE) Act of 2004. The law would allow patenting of obvious variations of inventions made under joint research agreements, if
(1) the claimed invention was made by or on behalf of parties to a joint research agreement (agreement) that was in effect on or before the date the claimed invention was made;
(2) the claimed invention was made as a result of activities undertaken within the scope of the agreement; and
(3) the application for patent for the claimed invention discloses, or is amended to disclose, the names of the parties to the agreement.