Request for Comments and Announcement of Workshop on Standard-Setting Issues, Project No. P111204 #00027 

Submission Number:
00027 
Commenter:
Jennifer Garner
Organization:
InterNational Committee for Information Technology Standards (INCITS)
State:
District of Columbia
Initiative Name:
Request for Comments and Announcement of Workshop on Standard-Setting Issues, Project No. P111204

NOTE: PDF version attached on INCITS letterhead. June 20, 2011 Federal Trade Commission Office of the Secretary 600 Pennsylvania Avenue, N.W. Room H-135 (Annex X) Washington, DC 20580 Re: Federal Trade Commission Request for Comments and Announcement of Workshop on Standards-Setting Issues (Patent Standards Workshop, Project No. P11-1204) To the Federal Trade Commission: The InterNational Committee for Information Technology Standards, INCITS, appreciates the opportunity to respond to your Request for Comments regarding the treatment of patented technology included in standards and the different ways that standards-setting organizations (SSOs) seek to minimize the risk of patent "hold-up". The patent disclosure rules used at INCITS are found in the Intellectual Property Rights section of the INCITS RD-1 “Policies and Guidelines”, located at http://www.incits.org/rd1/INCITS_RD1.pdf. In particular, INCITS adheres to the ANSI Patent Policy (see the ANSI Essential Requirements found at http://www.ansi.org/). The “Guidelines for Implementation of the ANSI Patent Policy”, also found at the ANSI web site, may be referenced for additional information. Over its lifetime, INCITS has developed well over 2,000 American National Standards in the ICT sector. The current officers and staff have not been notified of any active patent "hold-up" problems with regards to INCITS standards. This does not imply that there are no patent "hold-up" issues or that there are not concerns surrounding patent "hold-up". Sincerely, Jennifer Garner Director, Standards Programs InterNational Committee for Information Technology Standards (INCITS) 1101 K Street, N.W. Suite 610 Washington, DC 20005