Executive Advocacy
AIPLA regularly provides comments to different agencies within the U.S. government, as well as to other domestic organizations, on matters impacting intellectual property laws and protection.
Internal Revenue Service
- AIPLA Testimony on proposed revisions to 26 C.F.R. Parts 1 and 301, delivered February 21, 2008 before the Internal Revenue Service. (PDF)
- AIPLA Response to the October 2007 rule proposed by the U.S. Internal Revenue Service (IRS) on “Patented Transactions,”submitted December 26, 2007 (3 pages - 37K* - Click PDF to view the Response; click HERE to view the IRS proposed rule (10/22/2007)
National Academy of Sciences
- AIPLA Response to the National Research Council's Report on Reaping The Benefits of Genomic and Proteomic Research (31 pages –197K* Click HEREto view the Response; For information on the Report: Reaping the Benefits of Genomic and Proteomic Research: Intellectual Property Rights, Innovation, and Public Health, please visit The National Academies Press by clicking HERE.)
- AIPLA Response to the National Academies Report entitled "A Patent System for the 21st Century" (49 pages–243K* Click PDF to view the Response; Click PDF to view the Report.)
National Institutes of Health
- Comments on Draft Report to the Secretary of Health and Human Services: "Public Consultation Draft Report on Gene Patents and Licensing Practices and Their Impact on Patient Access to Genetic Tests" 74(52) Federal Register 11730 (March 19, 2009) ( PDF)
National Institute of Standards and Technology
- AIPLA Comments to NIST on March-In Rights Guidance, February 5, 2024 (PDF)
- AIPLA Feedback to NIST Draft Green Paper on ROI Initiative February 8, 2019 (PDF)
- AIPLA Response NIST Bayh-Dole Regulation, Dec 9, 2016 (PDF)
- AIPLA Comments to the National Institute of Standards and Technology (National Science and Technology Council's Sub-Committee on Standards) on Standardization Feedback for Sub-Committee on Standards, February 18, 2011 (PDF)
US Customs and Border Protection
- AIPLA Comments to U.S. Customs and Border Protection on Customs 21st Century Framework, February 2, 2019 (PDF)
- AIPLA Comments to U.S. Customs and Border Protection on Proposed Rulemaking, "Disclosure of Information for Certain Intellectual Property Rights Enforced at the Border," June 25, 2012 (PDF)
US International Trade Commission
- AIPLA Comments on the International Trade Commission’s Investigation of Trade-Related Aspects of Intellectual Property Rights (TRIPS Agreement), May 3, 2023 (PDF)
- AIPLA Comments on Proposed Amendments to the Commission's Rules of General Application, Adjudication and Enforcement, November 23, 2015 (PDF)
- AIPLA Comments on Commission FY2015 Budget and Space for Section 337 Investigations, May 19, 2014 (PDF)
- AIPLA Comments to U.S. Intellectual Property Enforcement Coordinator in Response to Request for Public Comments: "Interagency Review of Exclusion Order Enforcement Process," July 19, 2013 (PDF)
- AIPLA Comments on "Notice of Proposed Rulemaking on Rules of General Application, Adjudication, and Enforcement,” December 4, 2012 (PDF)
- AIPLA Comments on "Notice of Proposed Rulemaking on Rules of General Application, Adjudication, and Enforcement,” September 17, 2012 (PDF)
- AIPLA Comments on Proposed Revisions to Rules of Practice and Procedure and Proposed Handbook on Filing Procedures, August 5, 2011 (PDF)
- AIPLA Comments on proposed revisions to 19 C.F.R. Sections 201 and 210, filed March 19, 2008 at the US International Trade Commission (PDF)
US Securities and Exchange Commission
- AIPLA Comments to Concept Release on Business and Financial Disclosure Required by Regulation S-K, August 9, 2016 (PDF)
US Trade Representative
- Letter Submitted to the Office of the US Trade Representative Supporting US Opposition to TRIPS Waiver Proposal, March 30, 2021 (PDF)
- AIPLA Comments on the Draft Convention on the Recognition and Enforcement of Foreign Judgments Relating to Civil or Commercial Matters, March 19, 2018 (PDF)
- AIPLA and PhRMA Comments on Draft Convention on the Recognition and Enforcement of Foreign Judgments Relating to Civil or Commercial Matters Currently Being Negotiated at The Hague Conference on Private International Law, July 19, 2017 (PDF)
- AIPLA Comments on the proposed Anti-Counterfeiting Trade Agreement ("ACTA" or "Agreement") and the ongoing negotiations between the possible Member States, submitted September 27, 2010. (PDF)
- AIPLA Comments on the Proposed Amendment and Correction of Trademark Registrations published in the Federal Register on December 18, 2003 (Comments submitted February 2, 2004) (PDF)
- AIPLA Comments on the "Work Program set forth in the draft Ministerial Declaration submitted by the WTO General Council and WTO Director-General for consideration at the Fourth Session of the Ministerial Conference scheduled for Doha, Qatar next month" (October 11, 2001) (PDF)
Other
AIPLA Files Comments to Health and Human Services (HHS) on the World Health Organization's (WHO) Proposed Pandemic Treaty
- AIPLA Comments to HHS on WHO Pandemic Treaty, January 31, 2024 (PDF)
AIPLA Files Comments on Proposed Final Pretrial Conference Pilot and Order
- AIPLA Files Comments on Proposed Final Pretrial Conference Pilot and Order, August 26, 2022 (PDF)
AIPLA Comments to ACUS on Patent Small Claims Court
- AIPLA Comments on a Potential Small Claims Patent Court or Small Claims Patent Proceeding and its Impacts, July 5, 2022 (PDF)
Regarding the Position of the USPTO Director
- AIPLA Comments to the Department of Commerce Regarding the Position of USPTO Director, June 28, 2017 (PDF)
- AIPLA White Paper Concerning the Recommended Qualifications for the Next Director and Deputy Director of the U.S. Patent and Trademark Office, November 2013 (PDF)
Office of the Presidential Transition
- AIPLA Letter to Biden Administration, February 26, 2021 (PDF)
- AIPLA Letter to President-Elect Donald Trump, January 4, 2017 (PDF)
U.S. Intellectual Property Enforcement Coordinator
- AIPLA Comments to U.S. Intellectual Property Enforcement Coordinator on Development of the Joint Strategic Plan on Intellectual Property Enforcement, December 3, 2018 (PDF)
- AIPLA Comments to U.S. Intellectual Property Enforcement Coordinator on Development of the Joint Strategic Plan on Intellectual Property Enforcement, October 30, 2015 (PDF)
- AIPLA Comments to U.S. Intellectual Property Enforcement Coordinator in Response to Request for Public Comments: "Interagency Review of Exclusion Order Enforcement Process," July 19, 2013 (PDF)
- AIPLA Comments to OMB Regarding Negative Impact of Sequestration on USPTO Funding and Operations, May 21, 2013 (PDF)
- AIPLA Comments to U.S. Intellectual Property Enforcement Coordinator in Response to Request for Public Comments for "Trade Secret Theft Strategy Legislative Review," April 22, 2013 (PDF)
- AIPLA Comments to U.S. Intellectual Property Enforcement Coordinator on Development of the Joint Strategic Plan on Intellectual Property Enforcement, August 10, 2012 (PDF)
The Sedona Conference
- AIPLA Comments on the Sedona Conference Report on the Markman Process, submitted February 2, 2007 (PDF)
- AIPLA Comments on the Revised April 2005 Public Comment Draft" of The Sedona Guidelines: Best Practices Addressing Protective Orders, Confidentiality & Public Access in Civil Cases (the "Draft Guidelines"). Filed May 14, 2006. (PDF)
- Letter expressing initial concerns of AIPLA on the Revised April 2005 Public Comment Draft" of The Sedona Guidelines: Best Practices Addressing Protective Orders, Confidentiality & Public Access in Civil Cases (the "Draft Guidelines"). Filed March 10, 2006. (PDF)
Miscellaneous
- AIPLA Joint Comments to Mayor Eric Garcetti in Support of the Anti-Piracy Unit of the Los Angeles Police Department, March 9, 2018 (PDF)
In This Section
Recent Advocacy
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USPTO Announces Delay of Patent Filing Fee for Non-DOCX Applications
November 22, 2021
The United States Patent and Trademark Office (USPTO) issued a final rule to delay the effective date of the non-DOCX filing fee for an additional calendar year, until January 1, 2023. The fee adjustment would apply to any nonprovisional utility patent application filed under 35 U.S.C. 111, including any continuing application, that is not filed in DOCX format. The USPTO noted that this delay allows applicants additional time to adjust to filing patent applications in the new format and also enables the USPTO to conduct further testing of its systems. AIPLA was at the fore of expressing concern to the USPTO about requiring patent applications to be filed exclusively in a DOCX format, noting the potentially significant impact on its members and the system. -
AIPLA Submits Joint Letter to House Committee on Ways and Means Regarding Enforcement of Intellectual Property Rights at the Border
November 10, 2021
On November 10, 2021, AIPLA, alongside nine other entities, joined on a letter to House Committee on Ways and Means Chairman Richard Neal and Ranking Member Kevin Brady regarding enforcement of intellectual property rights at the border. The letter expressed concern with the flow of counterfeit goods across the United States border, calling for stronger, more effective trade enforcement and information sharing with the private sector. The letter encouraged support for pending legislation, including key provisions which will clarify CBP’s ability to share information with rights holders. -
AIPLA Submits Comments to U.S. Copyright Office Pursuant to Notice of Proposed Rulemaking Related to CASE Act Regulations
November 10, 2021
On November 10, 2021, AIPLA submitted comments to the U.S. Copyright Office pursuant to the Notice of Proposed Rulemaking (NPRM) related to CASE Act regulations. Comments provided included support for requiring claimants to provide contact information in the initial notice form and support for charging filing fees for counterclaims. A staggered fee structure was again suggested, and support was provided for an initial notice in a form that includes information required by the statute and additional basic information. An opt-out mechanism for claimants who receive a counterclaim was not supported, and concern was expressed regarding implementation of a mechanism whereby a respondent who has opted out of a CCB proceeding can change their mind and opt back in. -
AIPLA Submits Comments to USPTO Regarding Request for Information to Assist Preparation of Patent Eligibility Jurisprudence Study
October 15, 2021
On October 15, 2021, AIPLA submitted a comment letter to the United States Patent & Trademark Office (USPTO) following the Office’s request for information to assist in preparation of the Patent Eligibility Jurisprudence Study. In its comments, AIPLA addressed how the current state of patent eligibility jurisprudence in the U.S. affects patent protection in this country as compared to other jurisdictions (including instances of denial of patent protection in the U.S.), its impact on business strategies, the U.S. economy and the public as a whole. It was noted that, since 2012, Section 101 has been the most important issue facing AIPLA members and IP practitioners as they try to advise clients on how to best invest their limited resources. IP practitioners have been unable to advise clients with enough certainty about what inventions would be deemed patent eligible by patent examiners and later by the courts.