The concept of a "[[grace" period]], under which early disclosure does not prevent the discloser from later filing and obtaining a patent, must be distinguished here from the FTI system.<ref name=kravets>[https://techcrunch.com/2013/02/16/first-to-file-a-primer/ Kravets: "First-To-File Patent Law Is Imminent, But What Will It Mean?"]</ref> Germany and the UK formerly had a concept of grace period.<ref name=geresearch>[http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:52002DC0002:EN:HTML REPORT''Report FROMfrom THEthe EUROPEANEuropean COMMISSIONCommission TOto THEThe EUROPEANEuropean PARLIAMENTParliament ANDand EUROPEANEuropean COUNCILCouncil'' "An assessment of the implications for basic genetic engineering research of failure to publish, or late publication of, papers on subjects which could be patentable as required under Article 16(b) of Directive 98/44/EC on the legal protection of biotechnological inventions"]</ref> Both FTI and grace period systems afforded the early discloser protection against later filers. The FTI system allowed non-disclosers to overturn established parties, whereas the grace system only protects early disclosers. The US moved to a grace system on 16 March 2013, which has been termed "first-to-disclose" by some writers.<ref name=kravets/>
