The United States and Switzerland have emerged as the two hard- liners in opposing any operative decisions at the Doha Ministerial on TRIPS and Public Health or of any ‘understandings’ or ‘interpretations’ that would enable a member-country to issue compulsory licences under Article 31 of the Agreement, except on the ground of non-use (meaning patent holder not working the patent and not agreeing to license others to produce) and abuse of patent rights.