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UC Comment Letters

UC Office of the President

UC Comments on 2nd Notice of Proposed Regulation Amendments: Addition of Section100650 to Chapter 6 of Title 17 of the California Code of Regulations,and the California Institute of Regenerative Medicine (“CIRM”) IP Policyincorporated by reference into Section 100650

Abstract

This comment letter responds to the California Institute of Regenerative Medicine (CIRM)'s Second Notice of Proposed Regulation Amendments concerning the revised CIRM Intellectual Property (IP) Policy. The University of California (UC) expresses appreciation that CIRM addressed many concerns raised in UC’s earlier comments, but recommends several additional clarifications to improve the policy’s implementation, including narrowing and clarifying the definition of collaborators, correcting inconsistencies in publication-related materials provisions, aligning public-access requirements with NIH standards, facilitating material-transfer requests, and clarifying appeal procedures under CIRM’s march-in rights framework. UC’s recommendations are intended to promote research collaboration, technology transfer, and practical compliance with the policy.


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