In an appeal from the US Patent and Trademark Office Board of Patent Appeals and Interferences (Scott v Koyama, 61 USPQ 2d 1856 (Fed Cir Feb 27 2002)), an interference between a party (Koyama) that filed a patent application in Japan on March 13 1990 and a party (Scott) whose UK patent application was filed on March 29 1990, the Federal Circuit was faced with a situation in which neither party could rely on its actual reduction to practice of the invention. This was because the work was performed outside the US, and the applications were filed before January 1 1996. Had they been filed after that date, a statute (35 USC 104) permits the introduction of evidence concerning work performed anywhere in the world.