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           The difference in the legal system for protecting the scope of patents in various countries, not only imports new investments but also determines the technology transfer process of a country. Widespread protection causes the transfer of technology to be not easy despite the lack of protection because patent owners suffer losses. The two differences in intention resulted in the need for comparative studies on patent protection coverage in countries.

           There are two problems that must be explored, first what are the differences and similarities in the scope of patent protection in state regulations and the second how does the legal system affect different events? This problem will use the research method of a comprehensive statute approach and comparative approach, case approach, and conceptual approach. The results of the study found patent protection in European countries, the United States, Japan, and Indonesia have similarities in protection requirements that regulate new things, inventive steps, and industrial application. However, protection in the United States was initially to create temporary bases of other countries based on the first file. Then the scope of patent protection there was that Germany had implemented the widest protection, then the United States, and Japan, then the Netherlands. It means that the UK is a limited protection state. Differences in patent protection are influenced by the common law legal system which refers more to precedents than to civil law with its codification. Germany is the only country that applies rigid codification to patent protection. This means that Indonesia has limited patent protection coverage related to the limited cases resolved in court.

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