Comment from the Innovation Alliance

Summary: The Innovation Alliance, a coalition of R&D-based technology companies, supports the development of clear guidance that reinforces procedural safeguards for standards development organizations (SDOs) to ensure they remain procompetitive. They urge the Agencies to avoid providing affirmative guidance or safe-harbor treatment for licensing negotiation groups (LNGs), arguing that such groups may function as unlawful buyer cartels that suppress the value of patented technology.