Comment from Bilal Sayyed (Senior Competition Counsel at TechFreedom)
TechFreedomSupportAdvocacy
Summary: TechFreedom, a nonprofit technology policy think tank, supports the revision of the Collaboration Guidelines but argues they must be more specific regarding burden-shifting responsibilities. They advocate for a three-step rule of reason framework based on recent Supreme Court precedent, where the burden of identifying less restrictive alternatives rests with the government rather than the collaborating parties.
Additional Comments of TechFreedom