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in any patent claim describes a process, artefact or other phenomenon that is not
protean or evanescent.
6 Douglas ruled on a 1948 appeal case (lodged by Kalo Innoculant Co.) against
a patent granted to Funk Brothers Seed Company. A summary of the ruling
can be found at http://supreme.vlex.com/vid/funk-brothers-seed-v-kalo-inoculant-
20015972, accessed 16 December 2012.
7 The summary judgement can be found on the Supreme Court of Canada web-
site: http://scc.lexum.org/en/2004/2004scc34/2004scc34.html, accessed 10 Decem-
ber 2011.
8 Technically, most patents in biotechnological inventions are not like those granted
to Ananda Chakrabarty by the US Supreme Court in 1980. Indeed, judges of the
Canadian Supreme Court famously denied Harvard University patent rights to a
mouse used in cancer research (Oncomouse TM
)
in 2002. Part of their reasoning was
that the mice and their progeny were irreducible to the genetic modifications made
by Harvard biologists.
9 S trictly speaking, zoophilia is not the same as bestiality, though it may encompass it.
It is 'love of animals', and need not have a sexual component, though it does have an
emotional and often (non-sexual) physical component.
10 Bestiality is one of several human practices that appear to produce a reaction of dis-
gust in people that's very visceral. Is this reaction natural, traceable to evolutionary
processes that conferred an advantage on our historical predecessors? Some would say
so but, consistent with the arguments of Making sense of nature , others focus on either
(1) the social constitution of this reaction; or (2) the social mediation of this evolu-
tionary adaptation. Daniel Kelly's (2011) wonderful book Yu c k ! offers an up-to-date
survey that covers the various extant perspectives.
11 Quoted from the online repository of the Revised Code of Washington:
http://apps.leg.wa.gov/rcw/default.aspx?cite=16.52.205 , accessed 23 December 2011.
12 Previous anti-sodomy laws designed to outlaw homosexual behaviour between males
did, in fact, contain a provision against bestiality; however, after these laws were abol-
ished, in response to the arguments of the gay liberation movement from the 1970s
onwards, no new anti-bestiality law was created.
13 I should add that my own analysis can be said to be deeply anthropocentric because I
pay no attention to animal rights or welfare, nor do I consider seriously the (possibly)
ineffable 'otherness' of animals.
14 This distinction between human sex acts overlaps with the distinctions between 'cul-
ture' and 'nature', and 'reason' and 'passion'. As Robert Solomon details in his book
The passions , Western cultures have long sought to contain 'unbridled passion' because
it risks the submission of a person to their 'natural desires' (Solomon, 1993). Yet even a
moment's reflection reveals how difficult it is to maintain a secure distinction between
'good' sex and 'bad' sex and apply the distinction in practice on a consistent basis.
For instance, consider the couple, be they heterosexual or homosexual, who practise
'good sex' most of the time, but also participate in group sex or who enjoy masochistic
sex acts. How is such a couple to be regarded? How would they describe themselves
in light of the good/bad sex schema?
15 Zoo won an award at the internationally prestigious Sundance Film Festival and was
showcased at the 2007 Cannes Film Festival. Relatedly, the autobiographical book
The horseman: obsessions of a zoophile by Mark Mathews (not the author's real name)
commanded a lot of attention after its publication in 1994 (Mathews, 1994). This
included television coverage by the UK's Channel 4 in a documentary entitled Hidden
loves (broadcast in 1999).
16 The critic Susan Stryker distinguishes transgender from transsex rather too sharply:
for her the former is 'anything that disrupts, denaturalizes, rearticulates, and makes
visible the normative lineages we generally assume to exist between the biological
specificity of the sexually differentiated human body, the social roles and statuses
that a particular form of body is expected to occupy, the subjectively experienced
relationship between a gendered sense of self and social expectations of gender-role
 
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