Innovation vs Imagination in GenAI: A Comparative Patent Analysis of China, Europe, and the United States

In an era increasingly defined by artificial intelligence, the global race for technological supremacy has spurred diverse strategies among major powers. The dual pursuit of AI supremacy and self-reliance has led nations to explore distinct governance models, each seeking their unique route to the “holy grail” of tech supremacy. China, with a state-driven approach, prioritizes national goals and centralized planning (Ang et al., 2023; Chen et al., 2021), while the United States relies on a market-driven approach, facilitating innovation through profit-motivated competition in the free enterprise system (Popper et al., 2012). The European countries embrace a value-driven paradigm, which emphasizes the protection, promotion, and preservation of European values in AI development (Argyropoulou et al., 2019; European Commission, 2020).

The divergence in these governance models reveals a deeper conflict: the AI race is more than a tech competition; it is also a struggle over the values that should guide the development and use of AI technologies. Each AI innovation encapsulates a vision of what AI should be and the future it aspires to create (Jasanoff & Kim, 2009; Karizat et al., 2024). As these technologies compete for dominance in the market, the values and visions they represent inevitably clash. This collision of values forms a critical yet often overlooked theme in the ongoing “code war.”

To explore the technological trends and underlying value conflicts in the global AI race, this study systematically examines a total of 793,936 AI-related patents filed in China, Europe, and the United States. We employed a mixed-methods approach that combined computational techniques with interpretative text analysis to explore the following questions: What are the key tech trends revealed by GenAI patent filings? How do political, economic, and social realities influence the quantity and quality of GenAI patents? How do industry actors in China, Europe, and the U.S. frame the development of GenAI? What problems do they assert that GenAI should and can solve?

The findings indicate that China’s state-driven model has led to a high volume of patents but struggles with quality and global integration. Europe’s value-driven approach emphasizes ethical considerations and internationalization but struggles with low productivity, partly due to stringent regulations and fragmented innovation ecosystems. The U.S.’s market-driven system fosters impactful, commercially successful patents but risks monopolization due to patent concentration among a few dominant firms.

These findings underscore how each region’s governance system has woven its values and aspirations into its GenAI innovation. China’s state-driven approach foster patents that often frame GenAI as a socioeconomic issue, infusing totalitarian ideals and cybernetic mindsets into tech designs. It has raised serious concerns about patent quality, privacy infringement and disempowerment of civil society at large. The U.S. patents emphasize GenAI’s economic, entertaining, and health-related implications. The free-market approach has driven U.S. innovators to experiment with GenAI solutions for more profitable downstream operations. It has also enabled them to adeptly translate regulatory mandates and evolving ethical considerations into market drivers. Under a value-driven system, European patents are inclined to frame GenAI development as an ethical issue, producing GenAI solutions that are rich in ethical considerations, but may face challenges of low productivity and high latency. To foster a productive value-driven approach, Europe should consider deepening its economic integration and regulatory harmonization to activate the “Brussels Effect” in the realm of AI.