On January 4, 1938, Luther Burbank received U.S. Patent No. 267 on a Rose:
Burbank’s work helped to prompt the passage of the 1930 Plant Patent Act four years after his death. The Act made it possible to patent new varieties of plants. In his testimony before Congress in support of the Act, Thomas Edison testified “This [bill] will, I feel sure, give us many Burbanks.” Plant Patents No. 12, 13, 14, 15, 16, 18, 41, 65, 66, 235, 266, 267, 269, 290, 291, and 1041 all issued to Burband posthumously.