Three actions troubled the pharma lobby: In 2012, the Indian Patent Office granted India’s first compulsory licensing order in favour of Natco Pharma, allowing it to manufacture Nexavar, an anti-cancer drug patented by Bayer In 2005, Parliament _____________ Section 3(d) of the Patents Act and declined to provide intellectual property patent protection _____________ changes in drug formulations that did not result in “enhancement of the known efficacy of that substance“, a practice that is called “evergreening” In 2013, the Supreme Court refused to grant a patent for Novartis’ cancer drug Glivec, citing and upholding Section 3(d) Compulsory licensing is a provision governments can use to ensure _____________ of medicines in case of public health emergencies. Many in the government _____________ the 2012 order did not meet these rigorous benchmarks and was probably unnecessary. However, on Section 3(d) it would appear India is on good ground and the case against “evergreening” is strong.