This comment letter responds to the Department of Commerce Bureau of Industry and Security (BIS)'s proposed amendments to the Export Administration Regulations originally issued on July 29, 2024. UC supports BIS’s proposed amendments to the Export Administration Regulations as a careful effort to advance national security and foreign policy goals while recognizing the need to protect academic research and collaboration. UC endorses AUECO and COGR recommendations seeking additional exclusions for routine academic activities and clearer definitions of Military-Support End Users and Intelligence End Users to avoid unnecessary disruption to international research while still safeguarding critical technologies.
This comment letter responds to the Department of Commerce Bureau of Industry and Security (BIS)'s proposed amendments to the Export Administration Regulations originally issued on July 29, 2024. UC supports BIS’s proposed EAR amendments aimed at clarifying export controls and protecting privacy against unjustified government use of facial recognition and other mass-surveillance technologies. UC endorses AUECO and COGR recommendations for clearer Foreign-Security End User provisions and a more specific definition of facial recognition systems so regulators and institutions can better identify high-risk uses while excluding low-risk organizations and activities.
This comment letter responds the United States Patent and Trademark Office (USPTO)'s Notice of Proposed Rulemaking on terminal disclaimer practice to obviate nonstatutory double patenting. UC endorses the Association of University Technology Manangers (AUTM)’s opposition to the USPTO’s proposed terminal-disclaimer rule, arguing that it would undermine the enforceability and presumed validity of issued patents, create due process and coercion concerns, and exceed the USPTO’s administrative rulemaking authority. UC warns that the proposal would harm university technology transfer, deter investment in federally funded inventions, weaken the Bayh-Dole innovation framework, and reduce the market introduction of new technologies, so it urges USPTO to withdraw the rule.
This comment letter responds to the National Institute of Standards and Technology (NIST)’s request for information on the Draft Interagency Guidance Framework for Considering the Exercise of March-In Rights (Draft Framework) issued on December 8, 2023. UC strongly urges NIST not to issue the draft march-in framework, arguing that using Bayh-Dole march-in rights as a price-control tool would reinterpret the statute, conflict with congressional intent, and create uncertainty that could deter licensing, investment, public-private partnerships, and commercialization of federally funded university inventions. If NIST proceeds, UC asks it to revise and reissue the framework for public comment, including clear definitions and methods for terms such as “reasonable” price, “extreme,” “unjustified,” and “exploitative,” while ensuring the framework does not chill innovation across technology sectors.
This comment letter responds to NIST’s proposed revisions to regulations implementing the Bayh-Dole Act governing federally funded inventions and licensing of government-owned inventions. UC recommends clarifying that consumer pricing cannot be a basis for exercising federal march-in rights, providing greater flexibility in requirements related to small-business licensing preferences, and extending the period for converting provisional patent applications to non-provisional applications from ten to twelve months.
This comment letter responds to the U.S. Patent and Trademark Office’s request for comments on its National Strategy for Expanding American Innovation. UC supports increasing participation in invention and entrepreneurship and recommends federal support for educational programs, community partnerships and mentoring, improved access to capital, standardized data collection to measure participation and outcomes, and continued support for the Bayh-Dole Act and a strong patent system.
This comment letter responds to NIST’s request for information on rebuilding the Interagency Edison (iEdison) system for reporting federally funded inventions. UC strongly supports modernizing the system and recommends greater consistency in invention-reporting requirements across federal agencies, improved functionality to address outdated and burdensome processes, and continued stakeholder engagement in developing and testing the replacement system.
