Comment from John Kolakowski (Head of IP Policy and Advocacy, Americas at Nokia Technology Standards)
Nokia CorporationSupportBusiness
Summary: Nokia Corporation argues that the DOJ and FTC should recognize patent pools as pro-competitive while subjecting Licensee Negotiation Groups (LNGs) to close scrutiny as potential buyers' cartels. They also advocate for rigorous analysis of restrictive standards development, specifically criticizing the "royalty-free" model of the AV1 video codec for potentially suppressing competition and innovation.
Nokia Corporation respectfully submits the contents of the attached .pdf document in response to request of the DOJ and FTC for comments on potential additional guidance for collaborations among competitors, as first noticed on February 23, 2026.