​Recently, the USPTO declined a petition to extend inventorship to an artificial intelligence machine named DABUS. In the decision, the USPTO reasoned that Title 35 states "whoever invent," which suggests a natural person, and that an inventor who executes an oath or declaration must be a "person." The USPTO also referred to the Federal Circuit's decision in Univ. of Utah v. Max-Planck-Geselleschaft zur Forderung der Wissenchaften e.V., to support its conclusion that only a