Beyond the Code War: GenAI Patent Race Among China, Europe, and the United States (2005-2023)

In an era increasingly defined by artificial intelligence (AI), the global race for technological supremacy has spurred diverse strategies among major powers. This study examines 79,900 Generative AI (GenAI) patents filed between 2005 and 2023 in China, Europe, and the United States, uncovering how governance models shape innovation ecosystems, sociotechnical imaginaries, and regional innovation trends. Our findings indicate that China’s state-driven model has achieved the highest quantity of patents but significantly lags in all quality metrics. Conversely, Europe’s value-driven system has yielded a much smaller, but high-quality, portfolio of GenAI patents, while the U.S.’s market-driven system fosters impactful and commercially viable inventions but risks monopolization due to patent concentration among dominant firms. The study also reveals how regional patent discourses reflect distinct sociotechnical visions. We find that a techno-totalitarian vision prevails in Chinese patent discourses, which underscores GenAI’s potential to “smartify” every facet of society and empowers a total institution of perpetual surveillance. European patents place great emphasis on the ethical dimensions of GenAI development, particularly environmental protection and system security. This stands in contrast to U.S. inventions, which attend more to emerging AI ethics such as trustworthiness and algorithmic fairness, strategically integrating these values into their contextual discourses. This study illuminates how the AI race transcends a mere “code war,” encompassing a deeper value struggle with different visions competing for the social imagination about future technologies.