On June 16, 1980 the US Supreme Court in Diamond v Chakrabarty (a landmark case) determined genetically modified bacteria could be patented because such an invention constituted a “manufacture” or “composition of matter”, and though “micro-organisms are alive is withoug legal significance for the purpose of the patent law” [1, 2]
General Electric filed a US patent application for a genetically modified bacterium capable of breaking down crude oil (Pseudomonas putida), listing Ananda Mohan Chakrabarty as the inventor, but the application was rejected by a patent examiner, because under patent law at that time, living things were generally understood to not be patentable subject matter.