Antitrust and Consumer Protection

Competition: 2016, Vol 25, No. 2

COMMENTS ON PROPOSED UPDATE ON INTELLECTUAL PROPERTY LICENSING GUIDELINES

By Michael A. Carrier1

I applaud the agencies for updating the Intellectual Property (IP) Licensing Guidelines. I have two general reactions.

First, in these (or supplemental) guidelines, the agencies could consider addressing IP licensing issues related to (1) standard essential patents (SEPs), (2) patent assertion entities (PAEs), and (3) drug patent settlements. Although addressed in agency orders and speeches, each of these topics could benefit from further elaboration in the form of guidelines.

Second, to offer a more nuanced analysis, the agencies in three places could recognize the crucial regulatory and industry context.

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