text: As indicated above, some mammals typically used for food production (such as goats, sheep, pigs, and cows) have been modified to produce non-food products, a practice sometimes called pharming. Use of genetically modified goats has been approved by the FDA and EMA to produce ATryn, i.e. recombinant antithrombin, an anticoagulant protein drug. These products "produced by turning animals into drug-manufacturing machines by genetically modifying them" are sometimes termed biopharmaceuticals.
  The patentability of such biopharmaceuticals and their process of manufacture is uncertain. Probably, the biopharmaceuticals themselves so made are unpatentable, assuming that they are chemically identical to the preexisting drugs that they imitate. Several 19th century United States Supreme Court decisions hold that a previously known natural product manufactured by artificial means cannot be patented. An argument can be made for the patentability of the process for manufacturing a biopharmaceutical, however, because genetically modifying animals so that they will produce the drug is dissimilar to previous methods of manufacture; moreover, one Supreme Court decision seems to hold open that possibility.
  On the other hand, it has been suggested that the recent Supreme Court decision in Mayo v. Prometheus may create a problem in that, in accordance with the ruling in that case, "it may be said that such and such genes manufacture this protein in the same way they always did in a mammal, they produce the same product, and the genetic modification technology used is conventional, so that the steps of the process 'add nothing to the laws of nature that is not already present. If the argument prevailed in court, the process would also be ineligible for patent protection. This issue has not yet been decided in the courts.