Wendy Adams has found controversy in the court's belief in ethical neutrality in relation to animal welfare under the Canadian patent system. This idea is based on the idea that patents are fully constituted property rights, providing patentees with a default level of entitlement and would undoubtedly "skew the utilitarian calculus of animal welfare to the advantage of human animals and to the detriment of non-human animals." For that reason, Adams wrote that the ethical review of the treatment of animals should be an additional criterion for patentability. Abraham Drassinower has written that animal welfare issues that may arise in the course of patent applications are based on the fact that animals are considered property and these issues are best dealt with outside the confines of the Patent Act.