Submission Number: 00034 

Received: 7/29/2011 7:43:34 AM
Commenter: Anne Layne-Farrar
Organization: Compass Lexecon
State: Illinois
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Standard-Setting Issues, Project No. P111204
Attachments:
00034-80123.pdf Size = 486 KB
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Submission Text
While it is important to consider how standard setting bodies might improve their rules and practices in an effort to prevent patent hold up or other potential strategic behaviors, we also need to keep in mind how such rule changes might affect firms' incentives to participate in cooperative, voluntary standard setting efforts. The attached paper presents an economic model that demonstrates the imposition of an "incremental value rule" as a cap for patent licensing within a standards setting context would decrease incentives to participate in standards bodies and would reduce firms' incentives to invest in R&D. Thank you for your consideration, Anne Layne-Farrar