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UC Comment Letters

UC Office of the President

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

Abstract

This comment letter responds to the California Institute of Regenerative Medicine (CIRM)'s proposed amendments to its Intellectual Property (IP) Policy, including the addition of Section 100650 to the California Code of Regulations. The University of California (UC) expresses significant concern that the proposed policy imposes overly broad intellectual property, data-sharing, licensing, and commercialization obligations that extend beyond CIRM-funded research and could discourage research collaborations, technology transfer, commercialization, and scientific dissemination. UC recommends narrowing the policy's scope, limiting obligations to technologies directly resulting from CIRM-funded projects, preserving academic freedom and open scientific exchange, and avoiding retroactive application of new requirements to existing awards.


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