E-services are services that can be invoked over the Internet. One likely use of e-services would be to build business applications that can employ e-services from different service providers. This potential use of composite services in business settings highlights the issues of payment mechanisms, reliability, trust, inter-operability and service guarantees between different service providers. It also becomes essential to choose e-services that best fulfil the requirements of a particular business application. We investigate how patterns can be used in service composition to help in the development of business applications based on e-services.