One of the most distinguishable differences is that US patent system recognizes the principle of first use. So if someone tries to hijack your invention to apply for patent, you may claim that you are the first user, so you will be granted the patent right. Whether your invention has been used in public or not will not affect the ownership of the patent right.
However, China takes the principle of first application, so only the first applicant of an invention can be assigned of the patent right. Though you are the inventor, the first user, you are likely to lost your right to own the corresponding patent.
While, it may need a long discussion to express clearly the details. FYI. |