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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

  • AIPLA Submits Comments on Notification of Inquiry Regarding Copyright Alternative in Small-Claims Enforcement (“CASE”) Act Regulations

    April 26, 2021

    On April 26, 2021, AIPLA submitted comments to the U.S. Copyright Office on Notification of Inquiry regarding Copyright Alternative in Small-Claims Enforcement (“CASE”) Act Regulations. As a general matter, AIPLA believes that it is important to keep the procedures as straight forward and accessible as possible to ensure this will be a new, simple, and low-cost process to resolve small copyright claims. AIPLA encourages the Copyright Claims Board to publish standardized forms and instructions. Additionally, AIPLA is in favor of providing a Second Notice through the U.S. Postal Service. For ease of delivery, AIPLA is in favor of a Designated Agent directory. Online submission of opt-out notices should be encouraged, but a paper option is also recommended. To strike an appropriate balance of discovery, AIPLA recommends that the CCB require a standardized, initial disclosure of relevant information.
  • Letter Submitted to the Office of the US Trade Representative Supporting US Opposition to TRIPS Waiver Proposal

    March 30, 2021

    On March 30, 2021, AIPLA, along with IPO, LES USA and Canada, and the NY IP Law Association, submitted a letter to the Office of the US Trade Representative to express support for the United States’ opposition to the TRIPS waiver proposal being discussed at the World Trade Organization (WTO). The letter points out that the TRIPS waiver proposal would waive a variety of IP rights related “to prevention, containment or treatment” of COVID-19. The proposal incorrectly portrays IP as a barrier, but it is expressed, to the contrary, that IP protection enhances developments. The letter states that there are no known examples where IP has been used to limit access to COVID-related technology ‒ rather innovator companies have partnered and shared IP to create tools to address the pandemic. Should the proposed TRIPS waiver be implemented, it is noted that it would have an immediate chilling effect on continued research and necessary collaboration.
  • AIPLA Comments on the China National Intellectual Property Administration (CNIPA) Administrative Adjudication Measures for Early Resolution Mechanism for Drug Patent Disputes

    March 26, 2021

    On March 26, 2021, AIPLA submitted comments regarding the China National Intellectual Property Administration (CNIPA) Administrative Adjudication Measures for Early Resolution Mechanism for Drug Patent Disputes. In the comments, AIPLA requests clarification of handling of patent invalidity challenges, since substantial ambiguity remains. AIPLA requests an 8-month deadline to complete the adjudication in the Draft Measures, and requests extensions of notice periods and filing deadlines. AIPLA also requests that the Draft Measures include a corresponding provision providing that if a case has been accepted by either CNIPA or the People’s Court, any case subsequently filed in the other tribunal shall not be accepted on the same asserted claims. Finally, AIPLA requests that all possible appeals have been resolved or the time within which to appeal has expired without an appeal being filed.
  • AIPLA Submits Comments in Response to the Discussion Draft of The Digital Copyright Act (“DCA”)

    March 22, 2021

    On March 22, 2021, AIPLA submitted comments to Senator Thom Tillis in response to the discussion draft of The Digital Copyright Act (“DCA”) of 2021. AIPLA’s comments largely mirror and reflect AIPLA’s positions expressed on prior occasions, with comments directed to the concepts addressed and not to any specific proposed language. AIPLA’s comments support the concept of advancing the DMCA towards a “notice-and-staydown” regime. AIPLA also advocates further study into the use of a standardized unique identifier that would more effectively identify content.