Can our society's innovators thrive under our current unruly system? We cannot simply eradicate our current patent system and let parasites use ideas without compensating the original person who owned the idea. Nor can a strict law be enforced against patent infringers, because it dissolves any person or entity morally motivated to produce new innovations. John M. Golden (2010), in his article in Texas Law Review, suggests the anti-discrimination approach to limit favoring one party over another in patent appeals. He suggests limiting the validity period of patents. This does not necessarily give anyone the opportunity to profit from pre-existing patents, but rather sets the tone for patent controllers or large companies against small companies or inventors. Golden (2010) also suggests that the government agency, the PTO, should be given greater authority over what constitutes a patent and allow private parties to challenge the validity of new patents at the PTO. However, it could be disputed that the current PTO has difficulty reviewing and validating infractions; giving it more power would not be beneficial because the agency receives thousands of patent suits in a year (Golden, 2010). The name behind this concept is called “devolution,” which according to Golden, “gives discretion to private parties and the government” when it comes to handling cases (Golden, 2010). In resolving the limitations of patent holders, Golden (2010) briefly mentions that patents must be novel and non-obvious with respect to the distinct subject matter of the patented product or service among other prior patents. Golden (2010) also wants to restrict remedies for patent infringement by not giving patent owners the right to damages, but leaving it to the courts to decide the amount of the loss. Michelle Armond (2003) of the California Law Review suggests that courts recognize the "affirmative defense of independent invention" in preliminary injunction litigation. The idea is to focus on the conduct of the defendants rather than the plaintiffs, the patent owner, by analyzing the honest research and development procedures of the infringing companies (Armond, 2003). This gives small businesses the opportunity to protect themselves against patent trolls or threatening patent holders. Armond also supports the idea that patent infringement cases should settle remedies after trial and that courts should accurately analyze the claims filed by the patent owner to determine whether a permanent injunction should be appropriate (Armond, 2003 ). Furthermore, Armond (2003) suggests that courts should reach a conclusion before a remedy is granted to the patent owner..