Abhijit Das
email: abhijit.das@inria.fr

Chiara Galdi

Hu Han

Raghavendra Ramachandra

Jean-Luc Dugelay

Antitza Dantcheva

Recent Advances in Biometric Technology for Mobile Devices

à la diffusion de documents scientifiques de niveau recherche, publiés ou non, émanant des établissements d'enseignement et de recherche français ou étrangers, des laboratoires publics ou privés.

Introduction

Biometric recognition on mobile devices has drawn increased attention of the scientific community in the last decades, as evidenced by a set of related competitions at prominent pattern recognition and biometrics conferences [START_REF] Boulkenafet | A competition on generalized software-based face presentation attack detection in mobile scenarios[END_REF][START_REF] Zhang | The btas competition on mobile iris recognition[END_REF][START_REF] De Marsico | Insights into the results of miche i -mobile iris challenge evaluation[END_REF][START_REF] De Marsico | Results from miche ii mobile iris challenge evaluation ii[END_REF][START_REF] Günther | The 2013 face recognition evaluation in mobile environment[END_REF][START_REF] Khoury | The 2013 speaker recognition evaluation in mobile environment[END_REF][START_REF] Marcel | On the results of the first mobile biometry (mobio) face and speaker verification evaluation[END_REF], as well as by a rapidly growing number of related publications (see Figure 1 for the period 1997-2017, according to Scopus, matching keywords include biometrics, mobile devices, and smartphone). This scientific attention has been fueled by the prevalent commercial deployment of mobile biometrics as a robust authentication method on smartphones and other mobile devices. In addition, commercial organizations are involved in research projects, such as the Abacus project, introduced at Google I/O 2015, which aimed at replacing passwordbased authentication by an biometric-based authentication system. Related monitored biometric modalities include face, fingerprint, voice, patterns of typing, based on which a multimodal trust score was computed. Associated results on a 40TB multi-modal database show a false acceptance rate (FAR) of 1:1,000,000 [13].

In addition, the mobile biometrics market is projected to significantly expand, according to Acuity Market Intelligence, indicating that in 2019 all smartphones will have at least one integrated biometric technology. Similarly, according to Statista [12], by 2020 mobile biometrics will additionally be pervasive on wearable devices. This comes at a time, when TrendForce estimates the global smartphone production for 2018 at around 1.5 billion units [3]. Further, the introduction of applications such as Apple-pay is curving the need for highly reliable and secure mobile authentication [4]. Finally, financial institutes and banks are aiming to introduce online transactions on mobile platforms with biometric authentication [6]. Hence, biometrics is considered as the next generation mobile payment technique and related biometrics-embedded mobile devices are becoming increasingly popular.

Motivated by the above, we here aim to adhere to previous review works, including Meng et al. [START_REF] Meng | Surveying the development of biometric user authentication on mobile phones[END_REF], Wojciechowska et al. [START_REF] Wojciechowska | The overview of trends and challenges in mobile biometrics[END_REF], Baldini et al. [START_REF] Baldini | A survey of techniques for the identification of mobile phones using the physical fingerprints of the built-in components[END_REF] and Neal et al. [START_REF] Neal | Surveying biometric authentication for mobile device security[END_REF], by revisiting latest commercial solutions and recent papers from the years 2017-2018, as well as identifying added challenges that a biometric technology might face in mobile environment. Specifically we here place focal points on (a) what constitutes mobile biometrics and its specific challenges (Section 2) , (b) currently deployed commercial mobile biometric solutions (Section 3), (c) recent works in mobile biometrics (Section 4), as well as on (d) open research problems in the field (Section 5).

Mobile biometrics

A classical biometric system acquires biometric data from an individual (e.g., a fingerprint image), extracts a set of features from the data, and compares this feature set with templates in the database in order to verify a claimed identity or to determine an identity. Keeping in mind that this classical structure is also incorporated in mobile biometric systems, one could introduce following definition. A mobile biometric system is the entity that combines (i) embedded readers or sensors, as well as (ii) mobile applications, which process acquired data via (i), exploiting biometrics. Such a system can be built-in hand-held systems, as well as in smartphones or tablets [7].

Benefits of mobile biometrics

Mobile biometrics inherits a main part of benefits of classical biometrics, endorsing its own assets. Benefits associated to mobile biometrics include the following.

Portability: Due to compactness and high portability, mobile biometrics allows for an authentication at any time and in any place.

Cost effectiveness: The cost of performing biometric authentication on mobile devices is relatively low due to sensor technology and increasing computational power of the processing units embedded in the devices.

Market popularity and user acceptance: Due to the popularity and widespread use of mobile devices, the ease of use, as well as the acceptance of both, user and industry, have increased [START_REF] Goode | Bring your own finger how mobile is bringing biometrics to consumers[END_REF].

Challenges

Utilities related to mobile biometrics come along with challenges associated with acquisition, pre-processing, feature extraction, tempate storage that we proceed to describe.

Acquisition The sensors embedded in mobile devices, smartphones in particular, are constrained in size and cost. The former is of pertinence particularly for biometric traits such as fingerprints, palm prints, finger and hand veins. Additional factors concern the quality and heterogeneity of mobile-embedded microphones, which impact voice-based systems.

Sensor resolution may impact the accuracy of a biometric system based on face, periocular or, particularly, iris, since it relates to the amount of acquired features. However, the resolution of embedded digital cameras has greatly increased in the last decade. As an example, Samsung expanded from 8 to 13 megapixels between the 2011 Galaxy S2 and 2013 S4, then to 16 MP with 2014's Galaxy S5 [8]. In addition, new structured light RGB-D sensors have been recently deployed for smartphones, such as in iPhone X [5] or the recently announced Time of Flight (TOF) 3D Sensing Technology by Vivo [14], exploiting 3D face information, leading to an improved accuracy and robustness to presentation attacks.

While using mobile biometrics allows for identification at any time and in any place, it has to account for a great variability of acquisition conditions. Specifically environmental factors including illumination, temperature, humidity, noise, as well as human factors such as physical (e.g., resting, walking, seating) and psychological state of the user have a great impact on the quality of the biometric acquisition. For example, gait or movement based biometrics are restricted, when the user is resting. Table 1 gives an overview of further challenges and limitations of biometric modalities with regard to mobile environment and sensors.

Pre-processing Once acquired, biometric samples pass through a pre-processing step that aims to select from the raw data only the information necessary for biometric matching. This step may include segmentation, noise reduction, as well as shape and color normalization. For example, in the context of mobile iris recognition, segmentation has always been a challenge, in particular in the visible spectrum. Varying illumination, reflections, and occlusions make the process of extracting the iris area from an image extremely challenging [START_REF] Frucci | Idem: Iris detection on mobile devices[END_REF][START_REF] Reddy | A robust scheme for iris segmentation in mobile environment[END_REF]. Illumination and pose normalization are indispensable to reduce intra-class variations for face [START_REF] Olivares-Mercado | Face recognition system for smartphone based on lbp[END_REF].

Feature extraction Technological development has greatly reduced the gap between classical and mobile-based systems in terms of computational power. However the resources of a mobile device remain limited and the algorithms need to be designed to suit them. This brings to the fore the challenge of using memory and computationally intensive techniques, such as deep neural networks (DNNs) on mobile devices. This puts DNNs at direct odds with the power and performance constraints of embedded devices, necessitating algorithmic and software optimizations to make related algorithms suitable for deployment at the edge. It is essential that DNNs are executed within a power-constrained, computation-constrained, restricted environment, while maintaining the performance the networks would normally achieve in the cloud or even on a desktop PC [10]. Towards this, Qualcomm has recently unveiled the Vision Intelligence Platform, built to enable powerful visual computing and edge computing for machine learning on a wide range of IoT devices [11]. Other Temperature and humidity Touch-based gestures companies developing processors for deep learning on mobile devices include Intel Movidius, HiSilicon, ARM, and MediaTek. Huawei claims that its neural processing unit (NPU) can perform image recognition of 2,000 pictures per second, which the company also alleges is 20 times faster than a standard CPU [2]. We note that such a development in computational power of mobile devices will beyond doubt promote research, as well as use of more sophisticated models for mobile biometric applications.

Template storage Given that user biometric data is encrypted and stored within mobile devices, it is relatively easy for an adversary to appropriate the data, if the mobile phone can be accessed [START_REF] Wojciechowska | The overview of trends and challenges in mobile biometrics[END_REF]. While classical biometric systems are generally manipulated only by authorized personnel and are monitored (e.g., video surveillance), mobile devices are fully and only under the control of the owner. This security challenge requires the use of sophisticated encryption techniques to protect biometric data, as well as the employment of presentation attack detection to deny access to impostors.

Commercial solutions

In terms of sensor technology, smartphone biometrics in 2018 focused on Face ID (Apple), iris recognition (Samsung), with other brands mainly using capacitive fingerprint sensors "due to existing technical barriers". Vivo, which recently launched an Android smartphones, featuring an optical under-display fingerprint sensor, grew in production volume by 17% in 2017. At MWC Shanghai 2018, Vivo revealed its Time of Flight (TOF) 3D Sensing Technology, which detects the time it takes emitted pulse light to return to the sensor to accurately map objects at up to three meters in front of it. It enables new opportunities in facial, gesture and motion recognition, 3D photography and Augmented Reality (AR), expanding the capabilities of the next generation of smart devices.

Bloomberg recently reported that Google may adopt an iPhone-style "notch" in forthcoming smartphones, which could enable it to integrate 3D facial recognition cameras (from https://www.biometricupdate.com/ [START_REF] Burt | Smartphone growth to slow in 2018 as mobile biometrics mostly stay the course, trendforce predicts[END_REF]). An overview of the most recent biometric commer-cial solutions is summarized in Table 2. The table illustrates that currently modalities deployed by commercial products are predominantly related to face, fingerprint and iris.

Regarding mobile biometrics applications, it is expected that industry standardization initiatives like Visas Secure Remote Commerce will drive growth in remote biometric transactions, as the integration of biometric hardware in smartphones will increase, according to the research carried out by Juniper [START_REF] Moar | Juniper research[END_REF]. It was also predicted that more than 80% of smartphones would have some form of biometric hardware built-in by 2023. While fingerprint sensors are still the most common form of biometric hardware, facial recognition and iris scanning hardware integration will become more common, exceeding 1 billion devices.

Further, software Biometrics-as-a-Service offerings will be the main innovation in the field, Juniper reported. Software-based facial recognition is already supported by 90% of current smartphones, and 80% can support voice biometrics for payments. These services and behavior tracking technologies will allow cloud services to perform authentication in the background and across platforms, and Juniper estimated more than 1.5 billion smartphones would use software-based biometrics by 2023 (from https:// www.biometricupdate.com/ [6]).

Recent academic advances

In this section we review the most recent and innovative work on mobile biometrics. Apart from biometric recognition itself, several other aspects have been investigated by the research community, such as presentation attack detection and continuous authentication. This Section covers in particular approaches to overcome the challenges presented in Section 2.

Uni-modal approaches

Tables 3 and 4 report recent work on mobile biometrics in the period 2017-2018. Specifically Table 3 reflects the fact that modalities such as iris, face and periocular are predominant in mobile biometrics, which have been the main focus of the recent literature. In addition, a set of challenges mentioned in Section 2 such as robustness to acquisitioncondition and illumination have been addressed. Mobile [START_REF] Amjed | Noncircular iris segmentation based on weighted adaptive hough transform using smartphone database[END_REF]. Related recent advancement [START_REF] Amjed | Noncircular iris segmentation based on weighted adaptive hough transform using smartphone database[END_REF] employed weighted adaptive Hough transform on MICHE-II database and showed a high level of accuracy and more efficient computationally. In contrast to iris, the accuracy of periocular biometrics has significantly increased, given noisy acquisition, as experiments on the VISOB [START_REF] Rattani | Icip 2016 competition on mobile ocular biometric recognition[END_REF] and MICHE-II dataset showed. Therefore, it will be interesting to investigate viability of periocular biometrics in real life and moreover commercial devices for smart-phones having visible spectrum sensor. For both, iris and periocular biometrics publicly available datasets such as MICHE-II [START_REF] Castrillón-Santana | Mobile iris challenge evaluation ii: results from the icpr competition[END_REF], VISOB [START_REF] Rattani | Icip 2016 competition on mobile ocular biometric recognition[END_REF], VSSIRIS [START_REF] Raja | Smartphone based visible iris recognition using deep sparse filtering[END_REF] and CASIA-Iris Mobile V1.0 [START_REF] Zhang | Exploring complementary features for iris recognition on mobile devices[END_REF] have been employed. The detailed description of popular publicly available datasets can be found in Table 6.

In addition to classical biometric modalities, Table 3 showcases that recently new physiological biometric traits such as ECG, palmprint and hand geometry have been investigated in the context of mobile biometrics. Such traits have achieved accuracy of EER=0.5% for hand geometry and ECG, and EER = 7% for palmprint. Despite the fact that such traits are not yet established, related benefits are considerable. For example in the context of ECG, the spontaneous physiological signal is complementary to other physiological traits and can be used as a single trait for continuous authentication without user cooperation. It is notable that in most experiments related to new physiological trait, private datasets were explored, which brings to the need for public datasets that would enable benchmarking, in order to establish a state of the art. Recent works on mobile biometrics based on behavioral traits involve mainly gait, touch gesture, signature and keystroke (see Table 4). Among these traits gait is found to be the most investigated one. Significant results with very low EER=0.15% have been reported, considering both, constrained and unconstrained scenarios. We note that dataset size has been limited in such studies (maximum of 50 individuals). Similar to the new physiological traits the viability of behavioral traits for incorporation in commercial solutions is yet to be addressed and can be of great commercial interest.

Further advancements can be noticed in the feature extraction techniques for mobile biometrics. Similar to other computer vision and machine learning areas, mobile biometrics has rapidly and increasingly adopted DNN based methods (see Table 3). Given the skyrocketing performances of DNN-algorithms in recognition tasks, as well as the newest development of resource-preserving and lite DNN-architectures like Mobile Net [START_REF] Howard | Mobilenets: Efficient convolutional neural networks for mobile vision applications[END_REF], such architectures are expected to take over in mobile biometrics in the very near future.

The large heterogeneity of the mobile-embedded sensors and the rapid release of new models are not without consequences for mobile biometrics. As data comes from different acquisition sources, we face the challenge of crosssensor recognition, which has been investigated for palmprint [START_REF] Ungureanu | Unconstrained palmprint as a smartphone biometric[END_REF] and periocular [START_REF] Alonso-Fernandez | Log-likelihood score level fusion for improved cross-sensor smartphone periocular recognition[END_REF]. Similar studies also are necessary for other traits. The challenge of cross-sensor recognition concerns mainly server based authentication system as opposed to standalone applications.

Multi-modal approaches

As in classical biometric systems, the use of multiple biometric modalities is beneficial in mobile environment, as it can overcome a number of above-mentioned limitations. For example the overall accuracy of the system can be improved, unfavorable conditions for one modality can be compensated by the others, as well as attacking a system based on multiple modalities is more challenging, since it would involve the replication of multiple modalities. Re- 5. One interesting recent trend of research relates to the fusion of physiological and behavioral traits, which brings to the fore high recognition accuracies (due to the physiological trait), as well as continuous authentication (due to the behavioral trait). Satisfactory results of EER = 2.4% have been achieved in this area for example employing face and voice [START_REF] Findling | Mobile matchon-card authentication using offline-simplified models with gait and face biometrics[END_REF]. This is only a recent trend and it will be important to explore different traits, in order to find reasonable combinations of physiological and behavioral traits to attend a robust and reliable mobile solution.

Presentation attack detection

With the wide use of biometric technologies on mobile devices, presentation attack detection (PAD) is gaining high pertinence. While in this context biometric modalities such as fingerprint, palm print, and iris [START_REF] Wen | Face spoof detection with image distortion analysis[END_REF] are of lesser concern, face, which is easily acquired or obtained from social media and the related PAD on mobile devices, has attracted increased attention in recent years [START_REF] Wen | Face spoof detection with image distortion analysis[END_REF][START_REF] Patel | Secure face unlock: Spoof detection on smartphones[END_REF]. Promising results have been reported for different face presentation attacks, such as the photo attack, and the video replay attack. Zero-effort and live minimal-effort impersonation attacks under realistic scenarios were investigated in Muaaz and Mayrhofer [START_REF] Muaaz | Smartphone-based gait recognition: From authentication to imitation[END_REF]. A dataset of 35 participants, five professional actors, who are specialized in mimicking body movements and body language were employed to investigate gait based spoofing for techniques, proposed for mobile devices. Notable in this context is the OULU-NPU database [START_REF] Boulkenafet | Oulu-npu: A mobile face presentation attack database with real-world variations[END_REF], which is a mobile face PAD -database including real-world variations, including 5940 videos corresponding to 55 subjects recorded in three different environments using highresolution frontal cameras of six different smartphones. In a recent work [START_REF] Raja | Robust face presentation attack detection on smartphones : An approach based on variable focus[END_REF], Raja et al. presented a new approach exploring the intrinsic characteristics of the smartphone camera to capture a number of stack images in the depth-offield. The proposed system was entirely developed on the smartphone and exploited a stack of images with varying focus to effectively determine the presentation attacks. In 2017, a competition on generalized face PAD in mobile authentication scenarios [START_REF] Boulkenafet | A competition on generalized software-based face presentation attack detection in mobile scenarios[END_REF] was conducted, illumination conditions and presentation attack instruments (PAI) were employed to implement the attacks. The deep learningbased methods achieved impressive results. A future study was proposed, combining match scores with both PAD and quality measures, in order to improve the resilience of face verification systems. Spoofing detection for mobile biometrics performed a large development-leap, addressing a set of challenges associated to classical modalities. In contrast, such PAD solutions have not been commercially deployed yet. Moreover, PAD for modalities proposed recently in the context of mobile biometrics (for example multi-modal system based on fusion of physiological behavioral) is yet to be explored. Moreover, in contrast to classical biometrics, where PAD-techniques are associated to one specific biometric system and one specific acquisition sensor, mobile biometrics related PAD -techniques need to be robust to a number of acquisition sensors. This constitutes a challenging open research problem.

Continuous user authentication

Another recently explored novel area of research concerns continuous user authentication on mobile devices. The idea is to continuously monitor the identity, impeding presentation attacks of impostors. Crouse et al. [START_REF] Crouse | Continuous authentication of mobile user: Fusion of face image and inertial measurement unit data[END_REF] presented a related method based on face and Inertial Measurement Units (IMU). The effectiveness was evaluated on data collected from multiple Android smartphones and found to produce that the proposed person specific score level fusion achieved 9% in increase in true acceptance rate (TAR) in compression to the commercial off-the shelf (COTS) matcher.

Efficient and low latency detection of intruders in mobile active authentication can be found in Perera and Patel [START_REF] Perera | Efficient and low latency detection of intruders in mobile active authentication[END_REF]. A classical authentication system considers only a single enrolled subject. However, with the emergence of mobile devices, this concept has changed since a mobile device may be accessed by more than one user. In an additional work of Perera and Patel [START_REF] Perera | Efficient and low latency detection of intruders in mobile active authentication[END_REF], the issue of performance degradation associated to multiple user authentication (as opposed to single user authentication) has been addressed. The authors interpreted this challenge in an open-set framework and introduced the notion of probability of negativity to alleviate the effect of multiple users in authentication and further introduce a simple fusion scheme with the existing authentication methods to increase the intruder detection accuracy.

A major limitation of physiological modalities relates to the inability to authenticate the user continuously, when the information that the system is created to monitor, is not provided. On the other hand, due to the sporadic nature of human behavior, it currently seems impossible to solely rely on a behavioral system. Hence, an additional form of authentication is required to robustly handle different scenarios. Another important aspect is that a fair comparison between current works is not possible, due to the use of private datasets and nonuniform performance measures. Therefore, it would be of great interest to use established standards, that we proceed to enlist below.

Standards for mobile biometrics

Similar to traditional biometrics, towards the evaluation of the performance of a mobile biometric system, various types of standards have been defined. They are enlisted below.

Biometric Authentication: The performance evaluation of the biometric authentication on mobile devices is quantified in terms of the verification. However, the performance metrics for mobile devices are similar to that of the conventional biometrics systems. The recommended metrics following ISO/IEC 19795-1:2006 [START_REF]1: Principles and framework[END_REF] include the False Acceptance Rate (FAR) and False Reject Rate (FRR). The ISO/IEC 19795-1:2006 [START_REF]1: Principles and framework[END_REF] also provides the guidelines on evaluation protocols, data collection procedures, plotting of Receiver Operating Characteristics curve (ROC) and Detection Error Trade off (DET) curves. It is to be noted that, the performance reporting in terms of Equal Error Rate is not recommend following ISO/IEC 19795-1:2006 [START_REF]1: Principles and framework[END_REF].

Presentation Attack Detection: To evaluate the presentation attack detection algorithms on the mobile environments, the ISO/IEC 30107-3 [START_REF]Information technology -Biometric presentation attack detection -Part 3: Testing and reporting. Standard, International Organization for Standardization[END_REF] has recommended two important metrics namely: Bona fide Presentation Classification Error Rate (BPCER) and Attack Presentation Classification Error Rate (APCER). BPCER is defined as proportion of bona fide presentations incorrectly classified as attacks while APCER is defined as proportion of attack presentations incorrectly classified as bona-fide presentations. In addition one can also report the performance of the proposed method by reporting the value of BPCER while fixing the APCER to 5% and 10% corresponding to recommendations from IS0/IEC 30107-3 [START_REF]Information technology -Biometric presentation attack detection -Part 3: Testing and reporting. Standard, International Organization for Standardization[END_REF].

Vulnerability of the biometric system: Following the ISO/IEC 30107-3 [START_REF]Information technology -Biometric presentation attack detection -Part 3: Testing and reporting. Standard, International Organization for Standardization[END_REF], the vulnerability (or attack success rate) of the biometrics systems under attacks can be quantified using the metric -Impostor Attack Presentation Match Rate (IAPMR) which is defined as the proportion of impostor attack presentations using the same Attack Instrument species (morphed or averaged) in which the target reference is matched in a full-system evaluation of a verification system. For extended analysis on quantifying vulnerability on both academic and commercial biometric systems please refer to [START_REF] Scherhag | Biometric systems under morphing attacks: Assessment of morphing techniques and vulnerability reporting[END_REF].

Open research problems

Deviating from above described research areas, there are a number of novel aspects, which we proceed to identify. We envision that the addressing of such open research problems would advance the field socially, economically and technologically. We identify below three such open research problems.

Novel sensors and modalities

As mentioned above, the performance of a biometric system is among others a function of the acquisition technology. Hence, exploring new sensor technology, as well as analyzing cross-sensor authentication will certainly push the performance accuracy.

Exploring the viability of novel modalities for mobile biometric will also be beneficial. For example in Munalih and Ardianto [START_REF] Munalih | Finger vein biometrics: The future for a mobile authentication system[END_REF] finger vein recognition was one of the promising new modalities. In the commercial sector, Hitachi and Fujitsu actively research finger vein technologies. Recently, they have created a small and thin finger vein scanner for mobile devices. With the invention of the compact finger vein scanner, smart devices embedded with finger vein technology will soon be available on the market [9].

Novel applications

Since mobile phones are ubiquitous, novel applications are being proposed in the context of mobile biometrics [START_REF] Rahmawati | Digital signature on file using biometric fingerprint with fingerprint sensor on smartphone[END_REF], encryption and decryption of digital fingerprint are explored as digital signature. One application of high impact, benefiting from mobile biometrics relates to health monitoring. Herein physiological signal measurement using mobile devices is a field with recent rapid development. One of the important applications is heart rate (HR) estimation, which reflects the physical and emotional activities, e.g., exercise, emotion changes, illness, etc. The advantage of performing HR estimation using mobile devices is that it reduces the dependency to medical equipment, and thus improves the convenience to the users. However, robust HR on mobile devices is non-trivial because of the limited sensors in many of the mobile devices; in particular, not all the mobile devices have a photo plethysmography sensor and not all the scenarios are contact based. In this situation, it is required to perform physiological measurement such as HR measurement remotely (without contact) based on the commonly available visible light image sensor on mobile devices [START_REF] Niu | Continuous heart rate measurement from face: A robust rppg approach with distribution learning[END_REF][START_REF] Niu | Synrhythm: Learning a deep heart rate estimator from general to specific[END_REF]. The unconstrained illumination condition, pose variations, and low PSNR of the physiological signal captured by the visible light sensor pose great challenges to the measurement task. The literature of this area of research is not vast and there are many open research problem. Therefore, we expect it to be one of the directions for future research pertaining to mobile biometrics.

Novel privacy challenges

Storing biometric data on mobile devices raises additional challenges such as the protection of personal sensitive data / template protection. While the data should be protected from being stolen, the recovering of biometric information from the stolen data or linking the template to a person must be prevented. These concepts are referred to as irreversibility and unlinkability. Currently, template protection has received limited attention in the mobile biometrics literature. To this extent, in [START_REF] Stokkenes | Multi-biometric template protection on smartphones: An approach based on binarized statistical features and bloom filters[END_REF], Stokkenes et al. proposed a method for securing multiple biometric templates on smartphones, applying the concepts of Bloom filters along with binarized statistical image features descriptor. Obtained results indicate the robustness of the proposed system to preserve user privacy, while not compromising the inherent authentication accuracy without protected templates. On the other hand, template protection in classical biometrics has witnessed numerous works mainly based on four approaches: cancelable biometrics, BioHashing, Biometric Cryptosystems, and two-way partially homomorphic encryption, which can be easily adopted in the context of mobile biometrics. In addition to the above, the evaluation and analysis of modalities and relating technologies on larger scale are necessary to establish the scalability of mobile biometrics in real-life scenarios.

Conclusions

This article reviews biometric literature for mobile devices and suggests that research in mobile biometrics is on the rise. This is due to the recent commercial prevalence of mobile biometrics. In this article, we reviewed some of the recent methods, showing that face, fingerprint, and iris, are quite successfully deployed on mobile devices and largely accepted by the public. We discussed the benefits, limitations, as well as challenges with respect to biometric acquisition, processing, and biometric data storage and protection. Finally, we elaborated on some of the open research problems in the field.

Figure 1 .

 1 Figure 1. Graph of scientific papers published per year in the period 1997-2017 matching keywords including biometrics and mobile devices. From Scopus (https://www.scopus.com).

Table 1 .

 1 Challenges for biometric traits proposed for mobile environment.

	Modality/Factors	Environment	Physiological condition	Sensor
	Face	Illumination	Injury	Resolution
	Fingerprint Plamprint	Temperature and humidity	Fingerprint and skin condition Skin condition	Size
	Signature Voice	-Background noise	Physical and psychological state	Size, heterogeneity Heterogeneity
	Iris	Illumination	Injury	Resolution
	Gait	Ground condition
	Heart rate Keystroke	-	Physical and psychological state	Sensitivity

Table 2 .

 2 Latest commercial solutions for mobile biometrics.

	Provider	Solution name	Sensor	Modality	Application
	Samsung	Intelligent Scan Fingerprint scanner Capacitive sensor Infrared camera module and an infrared LED	Iris and face Fingerprint	Smartphone screen unlock, Secure Folder access, Samsung Pay
	Huawei	Face unlock Fingerprint scanner Capacitive sensor RGB camera	Face Fingerprint	Smartphone screen unlock
	Apple	Face ID Touch ID	TrueDepth Camera Capacitive sensor	3D Face Fingerprint	Smartphone screen unlock, Apple pay, unlock banking app and Paypal
			Time of Flight (TOF) 3D
	Vivo	Face ID	depth-sensing system with 300,000 sensor points	3D Face	Smartphone screen unlock
		Fingerprint scanner	Qualcomms ultrasonic In-Display Fingerprint Scanner	Fingerprint
	OnePlus	Face unlock	RGB camera	Face	Smartphone screen unlock
	Google	Smart Lock	Depends on the smartphone	Voice, fingerprint, or face	Smartphone screen unlock
	face recognition found to attend promising performance of
	AUC of 0.3 in both, constrained and unconstrained sce-

narios, validated on a private dataset. Noisy acquisition poses a remaining challenge in iris recognition in the visible spectrum. Specifically iris segmentation has shown to be challenging in this context

Table 3 .

 3 Recent development of mobile biometrics based on physiological traits. Abbreviations used: EER = Equal Error Rate; ISO = International Organization for Standardization; FNMR = False Non-Match Rate; AUC = Area Under Curve; AUROC = Area Under ROC curve; ROC = Receiver Operating Characteristics curve; RR = Recognition Rate; DEC = Decidability; ACC = Accuracy; CNN = Convolutional Neural Networks; LBP = Local Binary Pattern; SIFT = Scale Invariant Feature Transform

	Work	Modality	Technique	Dataset		Performance	Mobile challenge
	Barra et al.,	Hand ge-	Contact-less hand shape and	100 subjects 0.52% EER	Varying illumination
	2018 [22]	ometry	geometry analysis in visible
				light
	Wasnik et	Face	Quality assessment by ISO	101 subjects Error Reject Curve:	at	Intra-class	variation
	al.,	2017		standard			FNMR f = 0.1: iPhone	due to unconstrained
	[72]						6 Plus AUC of 0.0334,	acquisition
							Samsung S7 AUC of 0.03
	Rattani	Iris	Iris co-training	VISOB		13.5% EER	Intra-class	variation
	and Der-						due to unconstrained
	akhshani,						acquisition
	2017 [62]
	Galdi and	Iris	Iris color and texture feature ex-	MICHE-II		70% RR; 80% AUROC;	Noisy iris recognition
	Dugelay,		traction; fusion at score level			29% EER	in visible spectrum
	2017 [34]
	Abate et al.,	Iris	Statistical operators of Kurto-	MICHE-II		65% RR; 18% EER; 89%	Noisy iris recognition
	2017 [16]		sis and Skewness at pixel level;			AUROC; 1.80 DEC	in visible spectrum
				Self Organizing Map for clus-
				tering pixels of iris images
	Ahuja	et	Periocular Hybrid model: unsupervised	MICHE-II		MICHE-II: 98.6 % AUROC;	Intra-class	variation
	al.,	2017		and a supervised CNN, and	VISOB		5.3 % EER. VISIOB: 99.5%	due to unconstrained
	[18]			Root SIFT model			TPR at FPR of 0.001%	acquisition
	Fernandez	Periocular Log-likelihood score level fu-	VSSIRIS		6% EER (-40% EER for	Cross-sensor recogni-
	et al., 2017		sion of several comparators			cross-sensor)	tion
	[19]
	Ungureanu	Palmprint Collaborative Representation	81 subjects	86% RR; 7.4% EER	Cross-sensor recogni-
	et al., 2017		Classifier via Regularized	acquired			tion
	[70]			Least Squares classifier using	with	5
				Difference of Vertex Normal	smartphones
				Vectors
	Tan	and	Electrocar-	Two-stage classifier based on	184 subjects 99.52% ACC	Intra-class	variation
	Perkowski,	diogram	random forest and wavelet dis-				due to unconstrained
	2017 [68]	(ECG)	tance measure				acquisition
	cent work on mobile based multi-modal biometrics is sum-
	marized in Table

Table 4 .

 4 Recent development of mobile biometrics based on behavioral traits. Abbreviations used: CNN = Convolutional Neural Networks; DTW = Dynamic Time Warping; RF = Random Forest; EER = Equal Error Rate; FMR = False Match Rate; GMM = Gaussian Mixture Model; ACC = Accuracy; SVM = Support Vector Machine

	Work		Modality	Technique		Dataset	Performance	Mobile challenge
	Gadaleta and	Gait		Multi-stage decision making	50 subjects	0.15% EER	Transparent user authenti-
	Rossi, 2018			framework using CNNs and		cation
	[33]				SVMa to classify walking cy-
					cles
	Li and Bours,	Holding of	Gyroscope and accelerometer	304 subjects	22.72% EER	Continuous authentication
	2018 [42]		phone		based feature extraction, RF
					based classification, feature-
					level fusion
	Fierrez et al.,	Touch		GMM and SVM			UMDAA-02	Up to 3.1% EER	Inter-session comparison
	2018 [29]							[43]
	Muaaz and	Gait		DTW distance between gait	35 subjects	0% FMR	Impersonation Attack
	Mayrhofer,				cycles
	2017 [49]
	Wasnik et al.	Gait		Fusion of multiple compara-	48 subjects	1.31% EER	Natural variations
	2017 [73]				tors using Subjective Logic
	Fernandez-		Gait		Representative gait cycles se-	23 subjects	17.17% EER	Cross-comparison of gait
	Lopez et al.,			lection				cycles
	2017 [28]
	Tolosana et	Signature	Feature-based (global system)	e-BioSign [71] Intra-device:	Intra-device, inter-device,
	al., 2017 [69]			and time functions-based (lo-		10.1% EER; inter-	and mixed writing tool
					cal system)				device:	24.3%
									EER; mixed writ-
									ing tools: <1%
									EER
	Sun et al.,	Keystroke	Binary-class	identification	40 subjects	93% ACC	Continuous authentication
	2017 [67]				based on multi-view deep
					learning
	Table 5. Recent development of mobile biometrics based on multimodal systems. Abbreviations used: CNN = Convolutional Neural
	Networks; DTW = Dynamic Time Warping; LBP = Local Binary Pattern; EER = Equal Error Rate; RR = Recognition Rate; HOG =
	Histogram of Oriented Gradients; AUROC = Area Under ROC curve; ROC = Receiver Operating Characteristics curve; FRR = False
	Rejection Rate; FAR = False Acceptance Rate.
	Work		Modality	Technique		Dataset	Performance	Mobile challenge
	Zhang et al.,	Iris	and	CNN feature based weighted	CASIA-Iris-Mobile-	0.60% EER	Multi-modal recog-
	2018 [78]		periocular	fusion of iris and periocular	V1.0	nition
	Findling et al.	Gait and	Acceleration	based	gait	Yale-B [1], Panshot	Gait: 11.4%	Match-on-card bio-
	[30], 2018		face		match-on-card authentication	Face Unlock Database	ERR; Face:	metric recognition
								[31], Gait dataset [50]	2.4-5.4% EER
	Galdi et al.,	Face and	HOG; Sensor Pattern Noise	SOCRatES	97% RR	Secure authentica-
	2018 [35]		source						tion
			digital
			camera
	Ahmed et al.,	Iris	and	Multi-Block Transitional Lo-	MICHE-II	1.22% EER;	Intra-class variation
	2017 [17]		periocular	cal Binary Patterns; Fusion at		2.56% FRR at	due to unconstrained
					score level				FAR =0.001	acquisition
	Gofman	et	Face and	Hidden Markov Models		54 subjects	11.87% ERR	Intra-class variation
	al., 2017 [36]	voice						due to unconstrained
									acquisition

Table 6 .

 6 Publicly available datasets used in recent work on mobile biometrics.

	Dataset Modality Subjects	Acquiring setup
	MICHE Ocular	92	iPhone 5, Samsung
		images		Galaxy S4, Samsung
				Galaxy Tab II
	VISOB	Ocular	550	iPhone 5s, Samsung
		images		Note 4 and Oppo
	VSSIRIS Ocular	28	Nokia Lumia 1020 and
		images		iPhone 5S
	CASIA	Ocular	630	Mobile devices
	mobile	in NIR
	V1.0
	UMDAA-	Touch	48	Nexus 5
	02	gesture
		& face
	e-	Signature 70	Samsung Galaxy Note
	BioSign			10.1 and Samsung
				ATIV

Acknowledgement A. Das was supported by the research program FER4HM funded by Inria and CAS. C. Galdi and J.-L. Dugelay were supported by the EU Horizon 2020 research and innovation programme under grant agreement No. 700259. H. Han was supported by the External Cooperation Program of CAS (grant GJHZ1843). R. Raghavendra was supported by the Research Council of Norway under Grant No. IK-TPLUSS 248030/070. A. Dantcheva was supported by the French Government (National Research Agency, ANR) under grant agreement ANR-17-CE39-0002.


ACCESS TO MEDICINES IN DEVELOPING COUNTRIES: ETHICAL DEMANDS AND MORAL ECONOMY

Maurice Cassier, CNRS, Paris, Marilena Correa, UERJ, Rio de Janeiro Demands for access to pharmaceutical treatment have proliferated worldwide as a result of the HIV/Aids epidemic. In the late 1990s, the slogan of the South African organization Treatment Access Campaign in their street demonstrations was "Patients' Rights against Patent Rights". In 2006, Thai Aids patient organizations demanded the "right to life" as a justification for a "compulsory licence" decree allowing the production of generic medicines by copying patents without the patent-owner's authorization 1 . The Brazilian HIV/Aids patient organization ABIA decided in the same year to legally oppose a patent on the antiretroviral Tenofovir, frequently used in tri therapies, which was owned by Gilead. This opposition was filed in collaboration with the Indian HIV/Aids patient organization SAHARA. Their aim was to have Tenofovir put into the public domain, both in India and in Brazil. The arguments of these social movements that emerged in the context of the Aids epidemic and the arrival of highly sophisticated and expensive therapies had strong moral underpinnings: the right to life and the right to health, meaning social and global justice to access treatment that had until then been inaccessible to the world's poorest countries and people who had no social health insurance or other forms of mutual benefits. The demand for global justice underlay Act Up's calls for "Access for all" at the 1996 Montreal Aids congress. The accumulation of profits from vital goods was also condemned. In 1989, Act Up New York attempted to disrupt Wall Street when Glaxo Wellcome's shares skyrocketed following the publication of positive clinical results for AZT.

One of our hypotheses concerns the sudden appearance of these demands for access to medicines in the fields of political activism and the pharmaceutical economy, from the late 1990s. We posit that the arrival of new antiretroviral technologies was concomitant with the emergence of an ethic of universal access to treatment, conveyed by non-governmental organizations and by the health policies of certain countries of the global South, such as Brazil, Thailand

and Botswana, which we analyze in this issue of Developing World Bioethics. In a lecture in 1974 at the Rio de Janeiro Institute for Social Medicine, Michel Foucault pointed out the concomitance between the spread of antibiotics and the creation of health insurance in the 1940s 2 . The clash between these ethical demands and intellectual property was particularly strong in the late 1990s, when the World Trade Organization extended medicine patents to all developing countries that until then did not have them. Brazil and India, which were producing affordable generic medicines for the populations of developing countries, were strongly affected.

The social movements that were active in the field of medicines, where they explicitly demanded "the right to life" or "patient rights" as opposed to exclusive property rights or industrial monopoly (e.g. the Thai HIV/Aids organizations studied here by Stéphanie Rosenberg), corresponded to a biopolitics that was produced, promoted and supported by the individual and collective subjects who were gaining access to a new form of citizenship qualified as therapeutic citizenship or bio-citizenship by some authors (Nguyen, 2002, Biehl, 2009) 3 . This ethic of access to treatment was part of a demand for 2 Michel Foucault, "The Crisis of Medicine or the Crisis of Antimedicine?", 1st lecture on the history of medicine, Institute of Social Medicine, Rio de Janeiro, October 1974, Foucault Studies, No. 1, pp. 5-19, December 2004. 3 Vinh-Kim Nguyen, 2002, "Sida, ONG et la politique du témoignage en Afrique de l'Ouest" Anthropologie et Sociétés, vol 26, no. 1, pp 69-87; Joao Biehl, 2009, "Accès aux traitements "power over life", to maintain, safeguard and protect it, in the same spirit as Michel Foucault's hypothesis in "The Will to Knowledge" ("Right of Death and Power over Life") 4 . Foucault pointed out that "it was life more than the law that became the issue of political struggles, even if the latter were formulated through affirmations concerning rights". "The right to life" and "the right to health", demanded by patient organizations and by Médecins sans Frontières' Campaign for Access to Essential Medicines, participated in these "demands for rights". Ethics was thus a strategic weapon used by patients and populations to stand up to the proprietary pharmaceutical economy, if not to force it to change.

Foucault identified the emerging power of this "international citizenship" based on human rights, notably in the field of disease and health: "Amnesty International, Terre des Hommes and Médecins du Monde are initiatives that have created this new rightthat of the private individual to effectively intervene in the sphere of international policy and strategy" ("Confronting Governments: Human Rights", in J. Faubion, ed., Power, 2000), pp. 474-475).

The research published in this issue documents the actions of these civil society organizations in the field of government health policy during the negotiations of international organizationsthe WHO and the WTO -, and on the economic strategies of pharmaceutical laboratories.

In this issue we see that the actions of patient organizations and international NGOs such as MSF and Oxfam occupied both the public sphere and the legal sphere. Ethical demands resulted in learning about intellectual property rights and more generally economic rights, so as not to leave the field open to the experts of legal consulting firms or of the large pharmaceutical companies. Patient organizations in Brazil, India and Thailand created groups of experts on intellectual property to launch campaigns for compulsory licences or du sida, marchés des médicaments et citoyenneté dans le Brésil d'aujourd'hui", Sciences Sociales et santé, vol. 27, pp. 13-46. 4 Michel Foucault, The History of Sexuality: the Will to Knowledge, Volume 1, Penguin, 1998. to draft opposition documents addressed to the national industrial property institutes, demanding the invalidation of certain patents.

The shift of humanitarian medicine towards global therapeutic activism aimed at equal access to treatment has been analyzed by Peter Redfield in the case of MSF 5 . The NGO first advocated access to medicines as part of its humanitarian action when emergency medicine was confronted with the unavailability of treatments, either due to their cost or because manufacturers had given up producing them or doing research on the disease 6 . Humanitarian medicine highlighted the loss of efficacy of certain medicines which had not been replaced by new therapeutic solutions, due to pharmaceutical laboratories' lack of investment in R&D on tropical diseases. A "medicines unit" was created at MSF France in 1997 and a research group on "essential medicines" was set up. MSF adopted a strategy of publication in international medical journals to build the "neglected diseases" field and to remobilize the "essential medicines" field invented by the WHO in the 1970s 7 . In the late 1990s and early 2000s, the medical NGO created new organizations devoted to access to medicines: the Campaign for Access to Essential Medicines, known as the CAME, was founded in 1999, followed by the Drugs and Neglected Disease Initiative (DNDI), in 2003. The CAME was active in the field of law and the pharmaceutical economy, where it advocated for less stringent intellectual property rights so that treatments could be more readily available. It also produced a guide for purchasing antiretrovirals, designed especially for developing countries. The guide listed generics producers who could supply national and international medicines distribution programmes. MSF also published a guide on intellectual property rights (Drug Patent Report, 2003), for governments and civil society in developing countries. It was drafted by experts from the Oswaldo Cruz Foundation (Brazil), the DNDI, the Consumer Project on Technology in the USA, and the WHO. By creating the DNDI, MSF was moving into a new mode of intervention, that of pharmaceutical R&D, to invent new therapeutic solutions accessible to the poorest populations. The NGO continued to collaborate with the federal laboratory in Rio de Janeiro to support the development of fixed-dose generic combinations or paediatric formulations that had been unavailable until then. In 2002 it set up a pilot operation distributing Brazilian generics in a South African clinic, in collaboration with the local Treatment Action Campaign (TAC). MSF was thus active in various areas of the medicines economy: the regulation of intellectual property rights; the demand for new patented therapies to be included in the WHO's list of essential medicines; pharmaceutical R&D for neglected diseases; and the direct distribution of medicines. In so doing, it combined the moral economy, political economy and industrial economy of medicines, with a view to making them a "public good" accessible to everyone.

While the collective actions of patient organizations and international

NGOs played an essential part in building this new biopolitical field, the legal actions of patients or their families also participated in asserting demands for the "right to health" and the "right to life", to invent solutions for access to medicines. Work carried out by jurists and anthropologists in the Brazilian context enable us to analyze several rationalities in these legal actions. M. Ventura (2003), a lawyer working for HIV/Aids patient organizations, has shown jurists' work to assist patients who have instituted legal proceedings to obtain access to new antiretroviral therapies. These legal actions, initiated in the early 1990s, contributed to incorporating the right to health in jurisprudence and in the actual therapeutic care for patients. They precipitated the introduction of public programmes to distribute ARVs in the streets of Sao Paulo and Rio de Janeiro, followed by the federal law on free and universal access to ARVs, passed in 1996: "Legal actions constituted considerable jurisprudence that established the State's obligation to offer integral, free and universal treatment to carriers of the HIV virus" [START_REF] Ventura | Strategies to promote and guarantee the rights of people living with HIV/AIDS[END_REF] . M. Ventura referred to "a strategic use of the law" by patients and the organizations defending them, and to "a legal guerrilla for new rights" in the context of the democratization of Brazil. These lawyers organized seminars to make their arguments on the right to health known in legal circles.

Under the impetus of several patient organizations in Sao Paulo and Rio de Janeiro (GAPA, Grupo Pela Vidda) [START_REF]GAPA: Aids Support and Prevention Group; Grupo Pela Vidda: Group for the Valorization, Integration and Dignity of the Aids Patient[END_REF] , this legal action model spread to other States of Brazil. During this movement, legal actions were embedded in political campaigns to influence and define national health policy. In 1996 patient organizations were rallied to participate in the implementation of the national HIV/Aids programme, as experts.

Surveys undertaken a decade later by anthropologists J. Biehl and A.

Petryna 10 in the State of Rio Grande Do Sul show the steep increase in legal actions by poor people, often retired or unemployed, to obtain access to medicines for chronic or rare diseases. These actions were attempts to compensate for the shortcomings and inadequacies of the public medicine distribution programmes. They were based on the right to health enshrined in the Constitution, and relied on the legal assistance provided by the State. The judges' decisions, which were mostly in favour of the plaintiff, were grounded on "the constitutional right to health" and the "constitutional right to life". While Miriam Ventura has shown a legal and therapeutic activism tending towards the adoption of public health policies, Biehl and Petryna have underscored the fragility of these multiple legal actions by "patients citizens consumers" taking place in the gaps in public policy and in a fast-growing medicines market.

The ethics of access to medicines was not only used by patients, whether individually or collectively. It was also conveyed by the pastoral State (Foucault) 11 to protect its populations, by instituting forms of distributive justice and social security ("social property", defined by sociologist Robert Castel, to complete or make up for the flaws of private property) 12 . "Claims to rights" tended to be translated into laws following social protests or court cases. The demands of Brazilian sanitarist doctors in the 1970s and '80s resulted in the "right to health" being enshrined in the new Brazilian Constitution of 1988 (Loyola, 2009) 13 . This right served as a lever for new social and legal struggles in the HIV/Aids era. A Brazilian law in November 1996 provided for free universal access to treatment for HIV/Aids patients. In this issue, Fanny Chabrol analyses the convergence between the ethics of the State's pastoral power in Botswana, and the ethics of private philanthropy conveyed by a global health partnership between the Bill Gates Foundation and the pharmaceutical laboratory Merck, to supply a national programme of free distribution of ARVs.

The ethics of access to medicines has several sources: the "right to health" promoted by the pastoral State; the "right to live" demanded by patient organizations; and private philanthropy that initiated global health partnerships.

For pharmaceutical laboratories, it was also a matter of restoring the moral credit they had lost during the case they had made against the South African Medicine Act in 1998 (the international coalition of pharmaceutical laboratories finally withdrew charges in 2001, due to the extent of international public mobilization). In the early 2000s, the Brazilian federal pharmaceutical laboratory offered to transfer its technologies to African countries that wished to set up their own generic medicine production laboratories. In November 2003, the President of Brazil announced the construction of a pharmaceutical factory in Mozambique, to produce ARVs in the country 14 .

The invention of an ethics of access to medicines was globalized to a very large degree. One of the most noteworthy events of this emergence was in November 2001 during the negotiations of the World Trade Organization in Doha. The ethics of the right to health was thus consecrated in the areas of international trade regulation 15 . The Doha Declaration established the priority of the right to health over property rights. This meant that States were justified in cancelling exclusive patent rights on medicines to protect their populations. As the right to health suddenly emerged in trade negotiations, the WHO set up task forces on "intellectual property, innovation and public health", and published guidelines to help developing countries to introduce flexibilities in their patent laws, to protect public health (Carlos Correa, 2007) 16 . In this issue of DWB, German Velasquez, an economist and expert in intellectual property at the WHO, meticulously reports on the discussions of a group of experts commissioned by the General Assembly for Health, which examined the introduction of the right to health into the economy of pharmaceutical innovation. International NGOs such as MSF and DNDI were instrumental in producing and spreading this ethic of "the right to health" and "the right to life", and ensuring that it was incorporated into health policies. The CAME 14 Production was not launched until the end of 2013, primarily due to a particularly difficult technology transfer process. 15 While we are intent on following the geographic circulation of ethical arguments for access to medicines, we also need to endeavour to produce a history of norm changes in this respect. In the late 1990s and the very early 2000s, as calls for access to antiretrovirals in developing countries intensified, World Bank experts deemed this policy to be "inequitable": "The use of public funds to subsidise the treatment of patients in the poorest countries who are most able to complywho are better educated and have access to better health carewould be highly inequitable and would shift health resources from the poor to those who are not poor" (Ainsworth and Teokul, The Lancet, 2000, vol. 356, July 1). This change of norms was described by an MSF doctor, Pierre Chirac, who highlighted the ethical resistance to policies of universal access, by many experts who thought that "we don't treat anyone if we don't treat everyone" and that access to ARVs for HIV/Aids was "unfair with regard to other diseases" 17 .

It was the results of the Brazilian policy of universal and free distribution of Of note are the multiple feedback loops and interactions between ethics and law. At a conference on "medicines and the individual", jurists concluded that health law was opening to "…extra-judicial analyses drawing on economics, ethics or even social anthropology" (M. Bélanger) 20 . Several legal studies have highlighted the opening of international trade law to the right to health: "The decision of the TRIPS agreement in 2003 is certainly a major step forward as it is an international trade law text that is open to the protection of a non-market objective: the protection of health" (C. Jourdain-Fortier) 21 . In Human Rights and the WTO 22 , Holger Hestermeyer analysed the conflicts and compromises between commercial law and human rights. He concluded the book with recommendations for more cooperation between the WTO and the WHO: "In the matter of TRIPS and access to medicines a WTO panel could seek information from the WHO or the Committee on Economic, Social and Cultural Rights on the effects of patents on public health or the right to health". He recommended the use of an article from WTO agreements on intellectual property providing for an exception for security reasons, which could include threats to human health. This would enable States facing public health crises to refuse patents on medicines to treat pandemics. It is important to note here that intellectual property law itself took the right to health into account by providing for measures to safeguard the population: "We agree that the TRIPS Agreement does not and should not prevent Members from taking measures to protect public health. Accordingly, while reiterating our commitment to the TRIPS Agreement, we affirm that the Agreement can and should be interpreted and implemented in a manner supportive of WTO Members' right to protect public health and, in particular, to promote access to medicines for all" (Doha Declaration, WTO, 14 November 2001). The WTO Doha Declaration does in a sense make room for the pastoral State, protector of the population, as opposed to the State that guarantees the intellectual property of pharmaceutical inventions. To manage this tension, the DNDI Foundation proposed an approach combining the ethical principles of humanitarian medicine with pragmatism during the negotiations on IP rights on medicines that must be made accessible to those who need them the most: "The policy reflects the DNDI's philosophy, vision and mission ensuring that its products are accessible and affordable to patients who need them most. DNDI recognizes the reality of IP and seeks to implement its humanitarian mission using best, pragmatic practices for IP management" 23 .

The particularity of the point of view that we adopt here is that it focuses on and studies the process whereby human rights and ethics are put to work in "situated" actions, struggles and public policies, with regard to particular pathologies and therapies, in specific social histories and geographies. Peter Redfield (2008, op.cit.) refers to the combination of "Human Rights, Humanitarianism and the Practice of Virtue", to sum up the mobilization of human rights in the political practices and actions of humanitarian medicine.

The articles in this issue enable us to map the actors of this ethics of the right to health and the right to universal access to treatment. This is a "civil society" composed of patient organizations and NGOs such as MSF and Oxfam, which conduct actions at local and international level. These organizations ally and collaborate on a long-term basis with certain developing countries, especially with national programmes for the distribution of medicines in the case of Brazil and Thailand. Ministries of Health can include public health doctors and patient organization activists to coordinate measures providing access to medicines. In Brazil and Thailand, public laboratories producing generics are also leading actors in these campaigns and actions. In India, the private laboratory Cipla is a promoter of access to medicines, if not an activist. International experts from academia, patient organizations (Act Up), medical NGOs (MSF), intergovernmental organizations (WHO), and foundations (the chemists of the Clinton Foundation who are helping Brazilian laboratories for the copying of tenofovir) work towards the creation of programmes for access to medicines or for the regulation of intellectual property to make it more favourable to public health. The main funders of global health are also involved, to support national programmes. Despite initial reticence to finance universal access to treatment, the World Bank has helped Brazilian NGOs who advocate free access to generics, and the Bill Gates foundation has funded a programme for the distribution of ARVs set up by the Botswana government in partnership with the pharmaceutical laboratory Merck. In all these situations, governments, and particularly Ministries of Health, appear to be obligatory points of passage for foundations, non-governmental organizations or patient organizations. The cooperation and tension between MSF and the Brazilian Ministry of Health were crucial in forcing the Brazilian government to decide on a compulsory licence on patented medicines, in initiating the development of new therapies for malaria or leishmaniasis, and in evaluating the technological capacities of Brazilian laboratories to duplicate complex medicines 24 . In the situations that we have studied, biomedical humanitarianism is allied with the authorities of developing countries to distribute treatment or to break down the barriers of 24 In 2006, MSF and the Brazilian organization ABIA appealed to two internationally renowned chemists to assess the industrial capacities of Brazilian public and private laboratories. This expertise provided the Health Ministry with decisive information just when it was making a decision on a compulsory licence for Merck's Efavirenz: "ARV Production in Brazil. An Evaluation", J. Fortunak and O. Antunes, 2006. intellectual property. This seems to contradict the conclusions of Andrew Lakoff who insisted on a break between medical NGOs and State apparatus, probably with regard to the poorest countries, where the State is weaker than in Thailand or Brazil 25 .

We have explained the ethical demands for access to medicines in developing countries made through the mobilization of human rights, the right to health, and the right to life (Foucault), in order to influence intellectual property rights and health policies, and even to envision and implement new pharmaceutical economies (free distribution of medicines by the State, in Brazil and Thailand; or the therapeutic innovation systems studied by German Velasquez and Koichi Kameda in this issue). These demands and collective actions for access to treatment can also be justified by the notion of "moral economy" put forward by the English historian Edward Thompson in 1971, to explain the economic rationality of riots for a "fair price" of wheat and bread at the end of the 18 th century. At the time, the establishment of a capitalist market was overriding customary rights of access to bread for the poorest 26 . The advocacy of patient organizations and MSF for access to medicines and for measures to safeguard public health within IP law seems very similar to the rationality of the moral economy of popular protests for bread, analyzed by E.

Thompson 27 . This moral economy of medicines seems to underpin not only the ethical demands for access to treatment but also the pharmaceutical economies set up to distribute generic medicines or to develop new medicines against socalled neglected diseases, for example in the context of partnerships coordinated 25 Andrew Lakoff, 2010, Two Models of Global Health, Humanity: an International Journal of Human Rights, Humanitarism and Development, Vol 1, no. 1, pp. 59-79. 26 Edward Thompson, "The moral economy of the English crowd at the end of the eighteenth century", Past and Present, no. 50, pp. 76-136. 27 Anthropologist P. Redfield has also shown the analogy between working-class protests in the 18th century against the price of wheat, and MSF's positions for equal access to medicines: "…the feeling in and beyond MSF that the availability of goods such as medicines should not be governed solely by motives of profit", in "Doctors Without Borders and the Moral Economy of Pharmaceuticals" in Human Rights in Crisis, Edited by Alice Bullard, Ashgate, 2008, pp. 129-144. by the laboratory founded by MSF in 2003, the DNDI. Here ethics "informs" the real economy, in the sense of intervening to regulate intellectual property and the price of medicines (see the guidelines drawn up by the DNDI on the legal appropriation of medicines, which provide for either the non-patentability of inventions, or for the setting of royalty rates that are compatible with very low prices, and generally formulae of non-exclusive licences to facilitate the spread of the production of therapies) 28 . It is also this ethics of equal access to treatment that inspired MSF's proposal to organize a community of patents on ARVsa community that was hosted from July 2008 by UNITAIDS. However, the regulation of intellectual property by ethics has limits. Only the NIH and one pharmaceutical firm, Gilead, agreed to put their patents in this pool to be conceded to generics laboratories by way of non-exclusive licences. Gilead however drew up a list of beneficiary countries that excluded Brazil, where its patent on Tenofovir was contested by the federal pharmaceutical laboratory Farmanguinhos and by patient organizations.

Anthropological studies also show certain limits to the actions undertaken to secure access to treatment. Multiple individual legal actions for access to treatment are likely to create new inequalities in access to health (Biehl and Petryna, 2011, op.cit.). Lawyer Miriam Ventura has signalled the limits of legal actions focused on access to health, in a context of structural problems of access to employment29 . J. Biehl (2009, op.cit.) has also pointed out, in community-run sites called houses of support -casa de apoio -of Bahia, the limits of the poorest patients' inclusion in HIV/Aids therapeutic care programmes, despite the efforts of the State and NGOs to assist. This has revealed the fragilities of the acquisition of "therapeutic citizenship" in view of vertiginous social inequalities.

In his work on Botswana, F. Chabrol revealed the process of selection of eligible sites to set up global health programmesa process that closely intertwines management and philanthropy, to ensure a "promising" return on investments for the donation of medicines30 . Uganda, which at one stage was selected by the United States to host an ARV distribution programme, turned out to be too highly populated and too difficult to supply with medicines, whereas Botswana has a small population (2.5 million inhabitants) and a highly active Ministry of Health. The latter country was therefore ultimately chosen. German Velasquez's article introduces us into international negotiations held from 2006 to 2008 in the framework of an expert group responsible for devising new solutions for diseases affecting developing countries, and for making the therapies more accessible. These negotiations focused sharply on the pre-eminence of the right to health over commercial interests, on the use of international law to reinforce the right to health, where necessary through an international convention under the auspices of the WHO, and on the design of new models for the economics of innovation, to cover the needs of so-called neglected diseases. A convention of this nature could set up a public research fund to produce therapeutic inventions, also put into the public domain. German Velasquez' participation in these negotiations, as a WHO expert, has enabled him to describe the way in which power relations played out between groups of countries, as well as the formation of coalitions, for example between African or Latin American countries in Rio, to promote new solutions. This consortium inaugurated a new pharmaceutical innovation economy which prioritizes the sharing of knowledge, the production of medicines at very modest prices for patients in developing countries, and the non-patentability of treatment. The novelty of this system is that it brings together public and private organizations from the South and the North: several universities and hospitals from UK, France, Malaysia, Burkina Faso ; the Brazilian federal laboratory Farmanguinhos ; Aventis in France ; Cipla in India, under the governance of a non-profit organization, the DNDI. In other words, a form of moral economy in the field of medicines.

  See Holger Hestermeyer, Human Rights and the WTO. The Case of Patents and Access to Medicines, Oxford University Press, 2007. 16 Carlos Correa, 2007, Guidelines for the Examination of Pharmaceutical Patents: Developing a Public Health Perspective, ICTSD, WHO, UNCTAD, Geneva.

(

  Campaign for Access to Essential Medicines), initiated by MSF, was established in developing countries seen to be strategic (Brazil, South Africa, Thailand, India). NGOs organized world forums to promote access to medicines. We witnessed a global circulation of legal arguments within networks of patient organizations, as well as joint legal actions by several NGOs. Seminars in Rio de Janeiro brought together Brazilian and Indian jurists to work out opposition strategies to medicine patents. South-South circulation was superposed over North-South circulation via the legal assistance of certain foundations such as James Love's CPTech or organizations like Act Up. Global experts such as Carlos Correa, an Argentine academic jurist, assisted developing countries in strengthening their legal instruments to balance intellectual property and public health interests. They facilitated educational seminars on intellectual property in various regions of the world.

17

  Pierre Chirac, "Traitements ARVs dans les PED : historique et état des lieux", IMEA, 23 November 2010. ARVs that precipitated the change of health policy norms in this field. In fact, in 2003 the WHO appealed to the heads of the Brazilian programme to set up a world-wide system for the supply of HIV/Aids medicines and diagnostic tests in developing countries. The process of change of ethical norms took various routes and forms, consisting essentially in: a) "demands for rights" formulated in public petitions, street demonstrations, public campaigns by patient organizations to demand the application of compulsory licences or the implementation of national or global programmes for access to treatment; b) legal actions were taken by individuals or by patients associations to demand the application of the "right to health" enshrined in the Constitution ; c) ethical norms on access to treatment were codified in laws (the Brazilian law of 1996 on universal access to treatment for HIV/Aids) and incorporated into public health policies and measures ; d) opposition proceedings under the patent law and before the patent office that allow third partiesas patients associations or Ministry of health-to require the invalidation of patents and to have therapeutic inventions put into the public domain (see the articles of Juliana Veras and Stéphanie Rosenberg in this issue, on the case of Brazil). The ethical demands conveyed by social movements or by legal actions have the effect of mobilizing the law and "creating" it through jurisprudence : "…within this contextthe consolidation of brazilian democracy-it becomes very important to use law on behalf of public interest and to adopt litigation strategies used by the movement of people with Aids…" 18 . The lawyer Miriam Ventura has shown the inventive work of jurists who advised patient organizations in drawing up new interpretations of the right to health and the right to life. Federal judge Roger Raupp Rios, who analysed the legal responses to the Aids epidemic, spoke of "a fruitful dialogue that can be established between law-making and jurisprudence, public policies, and initiatives by civil society, all in a virtuous circle" 19 .

23

  Pragmatic and Principled: DNDI's Approach to IP Management, DNDI, 2007.

  The six articles in this special issue of DWB enable us to follow the emergence of this ethics of access to medicines from the late 1990s. By means of participant observation, two articles, those of Rachell Kindell Moore and of German Velasquez, study discussions and conflicts over access to medicines and intellectual property in the framework of international WHO negotiations at Doha in 2001, along with the work of the expert group appointed by the WHO in 2006. Four articles analyze in detail the ethical demands and mobilization of the right to health in several situations, as well as singular arrangements to organize access to treatment in Botswana, Brazil and Thailand, and in the framework of an international consortium to invent new medicines against malaria, the FACT (Fixed-Dose Artesunate Combination Therapy Project).Whereas we have situated the emergence of these ethical demands and aspirations within the context of the Aids epidemic and the arrival of antiretroviral tri-therapies in the late 1990s, the articles in this issue envisage other medical and social fields, particularly that of "neglected diseases". This concept was first put forward by MSF in international medical journals in the early 2000s 31 to mobilize various public institutions in the global South (the Oswaldo Cruz Foundation, the Indian Council of Medical Research, the Kenya Medical Research Institute, the Malaysian Ministry of Health), to develop new therapies that would be affordable for the poorest countries.Rachell Kindell Moore's article, "Access to Medicine and Distributive Justice: Breaching Doha's Ethical Threshold", focuses on access to treatment for non-transmissible diseases whose impact is increasing strongly in developing countries. It analyzes the sudden emergence of the right to health in WTO negotiations at Doha in 2001, and its continuation up to the present. The author shows that the Doha Declaration of November 2001 on the TRIPS Agreement and Public Health established the priority of justice in global health, a priority which seems to have been challenged in more recent negotiations on nontransmissible diseases.

  The article by Fanny Chabrol sums up meticulous anthropological research carried out at the Gaborone hospital and the Ministry of Health in Botswana, and at the Harvard School of Public Health in the USA, to study the implementation of the programme for free access to ARVs in this southern Koichi Kameda reports on a survey that he conducted on the international consortium set up in 2003 to develop new therapeutic combinations for malaria.

G. Krikorian,

2009, "The politics of patents: conditions of implementation of public health policy in Thailand" in S. Haunss and K.C. Shadlen (Eds), The Politics of Intellectual Property: Contestation over the Ownership, Use, and Control of Knowledge and Information (Edward Elgar, UK), pp. 29-55.

P. Redfield, "Doctors Without Borders and the Moral Economy of Pharmaceuticals" in Human Rights in Crisis, Edited by Alice Bullard, Ashgate 2008, p. 129-144.

Bradol J.H., Vidal C., 2010, Innovations médicales en situations humanitaires. Le travail de Médecins sans Frontières, L'Harmattan, Paris.

Jeremy Greene has pointed out that MSF became a mouthpiece for the "essential medicines" concept in the 2000s. "In distinguishing the ideal (essential drugs concept) from the real (WHO Model List of Essential Drugs List), MSF presented itself-a transnational NGO engaged in the process of getting drugs into bodies-as the new torch-bearer of the philosophy of essential medicines", in Making Medicines Essential: The Emergent Centrality of Pharmaceuticals in Global Health, BioSocieties Vol. 6, 1,10-33, 2011.

Ventura M, Divulgaçao em saude para Debate, Rio de Janiero, no. 27, August 2003, p. 242.

"Legal Response to the HIV/Aids Epidemic in Brazil", Divulgaçao em saude para Debate, Rio de Janiero, no. 27, August

2003, pp. 228-238. 20 Le médicament et la personne. Aspects de droit international, I. Moine-Dupuis (Ed.), Litec, 2007, Paris ; Clotilde Jourdain-Fortier, Santé et commerce international. Contribution à l'étude de la protection des valeurs non marchandes par le droit du commerce international, Travaux du Credimi, vol. 26, Paris, LexisNexis Litec, 2006, 699 pages.21 Le Médicament et la personne, Aspects de droit international. op. cit.22 Human Rights and the WTO, The case of Patents and Access to Medicines, Oxford University Press, 2007.

Banerji J. and Pecoul P., "Pragmatic and Principled: DNDi's approach to IP management" in Intellectual Property Management in Health and Agricultural Innovation: A Handbook of Best Practices A Krattiger, RT Mahoney, L Nelsen, et al. (Eds), MIHR: Oxford, U.K, 2007, p 1775-1782.

M.Ventura, 2003, op.cit., p.246.

F. Chabrol, "Prendre soin de sa population : Le Bostwana entre politiques globales du médicament et pratiques locales de citoyenneté", PhD thesis in sociology, EHESS, 2012.

P Trouiller et al., "Drug Development for Neglected Diseases: A Deficient Market and a Public Health Policy Failure", The Lancet 359 (2002): p. 2188.

African country. Botswana was chosen by Merck, the Gates Foundation and the US government once the local government was sufficiently equipped from a sanitary point of view to host and efficiently use the researchers, doctors and medicines from the US, and once the country was drawing sufficiently sure revenue from the mining economy to participate in supporting the programme.

Fanny Chabrol analyses the blind spots that appeared in this programme of free access to ARVs when the Botswana government demanded that patients be screened for eligibility, according to their nationality.

Whereas Botswana is absent from the arguments of international therapeutic activism, Stéphanie Rosenberg's article provides a richly documented analysis of the collective actions of patient organizations and international NGOs for access to treatment in two countries, Brazil and Thailand, which are, on the contrary, at the heart of conflicts over the right to health and the right to intellectual property. Patients' power is allied in these two countries with the Ministries of Health and the public laboratories which produce ARVs to supply their national Aids programmes. The ethical argument is a strategic instrument of patients' struggles to remove the obstacle of medicine patents.

In her article Juliana Veras sheds light on the legal battles of patent organizations and the Ministry of Health in Brazil to demand the cancellation of patents, so that generic medicines can be produced locally. She examines the circulation of legal arguments between Brazil, India and the US, and reveals the mediation of MSF. The battle was not only legal, but also technological and industrial. Juliana Veras' article describes very clearly the new public/private partnerships set up by the Brazilian authorities to produce a molecule that is very difficult to reproduce, Tenofovir, with the help of chemists of the Clinton Foundation. She points out "the moral dimension" of pharmaceutical inventions, associated with their accessibility and availability for patients' needs.