The Supreme Court's decision states:

".. (the respondent's invented) microorganism plainly qualifies as patentable subject matter. His claim is not to a hitherto unknown natural phenomenon, but to a non-naturally occurring manufacture or composition of matter-a product of human ingenuity "having a distinctive name, character (and) use ... . "Here ... , the patentee has produced a new bacterium with markedly different characteristics from any found in nature and one having the potential for significant utility. His discovery is not nature's handiwork, but his own; accordingly it is patentable subject matter under Section .... of U.S.C. ..."

Has the development of artificial life forms been encouraged by the Supreme Court's decision?