Comment from Frank Cullen Jr. (Executive Director of the Council for Innovation Promotion)

Summary: The Council for Innovation Promotion (C4IP) argues that the Agencies should refrain from issuing guidance on licensing negotiation groups (LNGs) because the legal landscape is unsettled and international positions diverge. They also advocate for including specific guidance on the antitrust risks of standards development organizations that lack FRAND commitments, citing concerns over innovation incentives and market distortions.