Agency Information Collection Activities; Proposed Collection; Comment Request; Project No. P131203 #00003

Submission Number:
00003
Commenter:
Michael Risch
Organization:
Villanova University
State:
Pennsylvania
Initiative Name:
Agency Information Collection Activities; Proposed Collection; Comment Request; Project No. P131203
Matter Number:

P131203

It is unclear why practicing companies are limited to wireless industries and not required to detail their patent holdings and portfolio organizations. This is a huge study that will cause a ton of work (I'm guessing way more work than your estimates for the largest PAEs and manufacturers). If the FTC is going to the trouble of doing a study, why not get it done right the first time and a) sample a larger number of manufacturers, in b) a more diverse area of manufacturing, and c) get identical information? The FTC will be in a much better position to analyze, compare, and otherwise report on findings. Without doing so, any report risks looking like so many others: a static look at an industry with no benchmark to compare it to.