There's already a system in place between participating countries where patents are "reserved" if they have been registered in another country. We don't need a "harmonized" patent system for this very reason.
And CERTAINLY, we don't need a harmonized patent system that follows the US' patent system. While the rest of the patent offices in the world have long realized that "first to invent" doesn't actually make the system any more fair than "first to register", it creates a lot more overhead when trying to grant patents (hence why there's such a backup in applications in the first place).
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