Executive Advocacy

AIPLA regularly provides comments to different agencies within the U.S. government, as well as to other domestic organizations, on matters impacting intellectual property laws and protection.


Click on the tabs below to explore some of AIPLA's executive advocacy efforts:


US Patent and Trademark Office

2018

  • AIPLA Comments on United States Patent and Trademark Office Draft Strategic Plan for FY 2018-2022, October 5, 2018 (PDF)
  • AIPLA Comments to the Patent Public Advisory Committee Public Hearing in the Proposed Patent Fee Schedule, September 11, 2018 (PDF)
  • AIPLA Comments on Determining Whether a Claim Element is Well-Understood, Routine, Conventional for Purposes of Subject Matter Eligibility ("​Berkheimer Memorandum"), August 13, 2018 (PDF)
  • AIPLA Comments on Changes to the Trademark Rules of Practice to Mandate Electronic Filing, July 25, 2018 (PDF)
  • AIPLA Comments on the Changes to the Claim Construction Standard for Interpreting Claims in Trial Proceedings Before the Patent Trial and Appeal Board, July 9, 2018 (PDF)
  • AIPLA Comments on the Draft Convention on the Recognition and Enforcement of Foreign Judgments Relating to Civil or Commercial Matters, March 19, 2018 (PDF)
  • AIPLA Comments to the Current TTAB Standard Protective Order, effective June 24, 2016 (January 2, 2018) (PDF)

2017

  • AIPLA Comments to Improving the Accuracy of the Trademark Register:  Request for Comments on Possible Streamlined Version of Cancellation Proceedings on Grounds of Abandonment and Nonuse, August 1, 2017 (PDF​)
  • AIPLA Statement on Fraudulent and Misleading Solicitations to Trademark Owners, USPTO Public Roundtable on Fraudulent and Misleading Solicitations, July 26, 2017 (PDF)
  • AIPLA and PhRMA Comments on Draft Convention on the Recognition and Enforcement of Foreign Judgments Relating to Civil or Commercial Matters​ Currently Being Negotiated at The Hague Conference on Private International Law​, July 19, 2017 (PDF​)​
  • AIPLA Comments on PTAB Procedural Reform Initiative, July 14, 2017 (PDF​)
  • AIPLA Recommendations to the Patent Public Advisory Committee (PPAC), July 6, 2017 (PDF​)
  • AIPLA Comment for Consideration by the Working Group on Regulatory Reforms  in Relation to Executive Order 13771 (“Presidential Executive Order on Reducing and Controlling Regulatory Costs”) and Executive Order 13777 (“Presidential Executive Order on Enforcing the Regulatory Reform Agenda”), June 23, 2017 (PDF​)
  • AIPLA Comments on Examination Guide Entitled “Incapable Informational Matter”​, March 15, 2017 (PDF​)
  • AIPLA Comments Regarding the Continuation of the Accelerated Examination Program​, March 13, 2017 (PDF​)
  • AIPLA Comments of the AIPLA on Examination Time Goals, January 26, 2017 (PDF​)
  • AIPLA Comments on Patent Eligibility after Section 101 Roundtables, January 18, 2017 (PDF)
  • AIPLA Comments on a Preliminary Draft Convention on the Recognition and Enforcement of Foreign Judgments Currently Being Negotiated at The Hague Conference on Private International Law​, January 18, 2017 (PDF​)

2016

  • AIPLA Comments on Revival and Reinstatement of Abandoned/Cancelled/Expired Trademarks​,​ Dec 23, 2016 (PDF​)
  • AIPLA Comments on Duty of Disclosure, Dec 22, 2016 (PDF​)
  • AIPLA Comments on Proposed ST.26 Standard for Sequence Listings​, Dec 21, 2016 (PDF​)
  • AIPLA Comments on Proposed Rule Recognizing Privileged Communications between Clients and Patent Practitioners at the Patent Trial and Appeal Board​, Dec 19, 2016 (PDF​)
  • AIPLA Comments on USPTO Patent Fee Proposal FY2017, Dec 2, 2016 (PDF​)
  • AIPLA Comments on Post-Prosecution Pilot Program (P3), Nov 8 2016​ (PDF​)
  • AIPLA Comments on Leveraging Electronic Resources to Retrieve Information from Applicant's Other Applications and Streamline Patent Issuance, Nov 8 2016​ (PDF)
  • AIPLA Comments on Continuation of Random Audit Pilot Program, August 17, 2016 (PDF​)
  • AIPLA Comments to USPTO on TM Fees Proposal​, July 11, 2016 (PDF​)
  • AIPLA Comments on Written Description Requirements in Design Applications​, June 14, 2016 (PDF​)
  • AIPLA Comments on Proposed Amendments to TTAB rules, June 3, 2016 (PDF)
  • AIPLA Patent Quality Metrics Comments, May 24, 2016 (PDF​​)
  • AIPLA Response to Submission of Topics for USPTO Quality Case Studies (Consolidated), February 12, 2016 (PDF)

2015

  • AIPLA Comments to the Department of Commerce and USPTO on the Shared Services Initiative, December 14, 2015 (PDF)
  • AIPLA Comments on Proposed Patent Fee Schedule Considered at the Public Hearing by the Patent Public Advisory Committee, November 25, 2015 (PDF)
  • AIPLA Comments on Proposed Trademark Fee Schedule Considered at Public Hearing by the Trademark Public Advisory Committee, November 10, 2015 (PDF)
  • AIPLA Comments in Response to the Request for Comments on the "July 2015 Update on Subject Matter Eligibility," October 28, 2015 (PDF)
  • AIPLA Comments in Response to Proposed “Amendments to the Rules of Practice for Trials Before the Patent Trial and Appeal Board," October 21, 2015 (PDF)
  • AIPLA Comments in Response to "Request for Comments on Enhancing Patent Quality," May 20, 2015 (PDF)
  • AIPLA Comments in Response to the USPTO "Request for Comments on 2014 Interim Guidance on Patent Subject Matter Eligibility," March 16, 2015 (PDF)
  • AIPLA Comments on USPTO Draft Examination Guide on "Repeating-Pattern Marks," March 16, 2015 (PDF)
  • AIPLA Comments in Response to the USPTO "Notice of Roundtable and Request for Comments on Domestic and International Issues Related to Privileged Communications Between Patent Practitioners and Their Clients,"March 6, 2015 (PDF)
  • AIPLA Recommendation Regarding Consideration by the PCT Receiving Office of the USPTO of Requests for Restoration of Priority Based Upon the “Due Care” Standard, February 24, 2015 (PDF)
  • AIPLA Recommendation Regarding Deference to Favorable Findings of the International Searching Authority of the USPTO During Examination of a U.S. National Phase from a PCT Application, January 13, 2015 (PDF)

2014

  • AIPLA Comments in Response to the USPTO Announcement, “Trademark:  Next Generation Acceptable Identification of Goods and Services Manual,” December 16, 2014 (PDF)
  • AIPLA Comments in Response to the USPTO Announcement, “Request for Comments on Proposal to Allow Amendments to Identifications of Goods and Services Due to Technology Evolution,” October 30, 2014 (PDF)
  • AIPLA Response to the "Request for Comments on Trial Proceedings Under the America Invents Act Before the Patent Trial and Appeal Board," October 16, 2014 (PDF)
  • AIPLA Response to "Request for Comments on Optimum First Action and Total Pendency," September 8, 2014 (PDF)
  • AIPLA Response to the Notice of Proposed Rulemaking Entitled, "Changes to Facilitate Applicant's Authorization of Access to Unpublished U.S. Patent Applications by Foreign Intellectual Property Offices," September 8, 2014 (PDF)
  • AIPLA Response to the Notice of Proposed Rulemaking Entitled, "Changes to Patent Term Adjustment in View of the Federal Circuit Decision in Novartis v. Lee," August 13, 2014 (PDF)
  • AIPLA Response to "Request for Comments and Extension of Comment Period on Examination Instruction and Guidance Pertaining to Patent Eligible Subject Matter (re: Alice), July 31, 2014 (PDF)
  • AIPLA Comments on "Guidance for Determining Subject Matter Eligibility of Claims Reciting or Involving Laws of Nature, Natural Phenomena, and Natural Products," (re: Myriad), July 31, 2014 (PDF)
  • AIPLA Response to "Request for Comments on Virtual Marking," July 16, 2014 (PDF)
  • AIPLA Comments in Response to the USPTO Announcement, "Share Comments/Suggestions on Draft Examination Guide:  Service Mark Specimens," July 16, 2014 (PDF)
  • AIPLA Comments on the Notice of Proposed Rulemaking, "Reduction of Fees for Trademark Applications and Renewals," June 23, 2014 (PDF)
  • AIPLA Response to "Request for Comments on the Use of Crowdsourcing and Third-Party Preissuance Submissions To Identify Relevant Prior Art," April 25, 2014 (PDF)
  • AIPLA Response to the Notice of Proposed Rulemaking (Extension of Comment Period):  "Changes to Require Identification of Attributable Owner," April 24, 2014 (PDF)
  • AIPLA Response to "Request for Comments and Notice of Roundtable Event on the Written Description Requirement for Design Applications," March 14, 2014 (PDF)
  • AIPLA Comments on "Changes To Implement the Hague Agreement Concerning International Registration of Industrial Designs," January 31, 2014 (PDF)
  • AIPLA Response to "Request for Comments on Methods for Studying the Diversity of Patent Applicants," January 31, 2014 (PDF)

2013

  • AIPLA Response to "Request for Comments:  Post Registration Amendments to Identifications of Goods and Services Due to Technology Evolution," December 2, 2013 (PDF)
  • AIPLA Comments on USPTO Draft Strategic Plan for Fiscal Years 2014-2018, November 27, 2013 (PDF)
  • AIPLA Comments in Response to the USPTO Announcement, "Share Comments/Suggestions on Draft of Examination Guide:  Applications for Marks Comprised of gTLDs for Domain Name Registration or Registry Services," September 6, 2013 (PDF)
  • AIPLA Comments on "Changes To Implement the Patent Law Treaty," June 10, 2013 (PDF)
  • AIPLA Recommendation Regarding Automatic Applicant Authorization for USPTO To Transmit Pre-Publication Search Results to Foreign Patent Offices, May 22, 2013 (PDF)
  • AIPLA Comments to OMB Regarding Negative Impact of Sequestration on USPTO Funding and Operations, May 21, 2013 (PDF)
  • AIPLA Recommendations for Reducing Paperwork, Time, and Cost for the Office and Applicants With Respect to Sequence Listings, May 20, 2013 (PDF)
  • AIPLA Response to "Request for Comments on a Patent Small Claims Proceeding in the United States," April 30, 2013 (PDF)
  • AIPLA Response to "Request for Comments and Notice of Roundtable Events for Partnership for Enhancement of Quality of Software-Related Patents," April 12, 2013 (PDF)
  • AIPLA Comments on Preparation of Patent Applications, March 15, 2013 (PDF)
  • AIPLA Comments on Matters Related to the Harmonization of Substantive Patent Law, February 28, 2013 (PDF)
  • AIPLA Written Comments in Relation to Leahy-Smith America Invents Act Section 27 Genetic Testing Study and Public Roundtable, February 8, 2013 (PDF)​
  • AIPLA Comments on "Request for Continued Examination (RCE) Practice," February 4, 2013 (PDF)
  • AIPLA Comments on Proposed Requirements for Recordation of Real-Party-in-Interest Information Throughout Application Pendency and Patent Term, January 25, 2013 (PDF)​
Copyright Office
  • AIPLA Comments Submitted Pursuant to "Notice of Proposed Rulemaking on Copyright Office Fees," September 21, 2018 (PDF)
  • AIPLA Comments Submitted Pursuant to Request for Additional Comments Regarding Section 512 Study​, ​February 21, 2017 (PDF)
  • AIPLA Comments on IT Modernization Plan​, March 31, 2016 (PDF)
  • AIPLA Comments on 1201 Study​, March 3, 2016 (PDF​)
  • AIPLA Comments in response to the US Copyright Office Request for Comments Regarding "Mass Digitization Pilot Program," October 9, 2015 (PDF)
  • AIPLA Comments Submitted Pursuant to Notice of Inquiry Regarding "Copyright Protection for Certain Visual Works," July 23, 2015 (PDF)
  • AIPLA Comments Submitted Pursuant to Notices of Inquiry Entitled “Orphan Works and Mass Digitization; Request for Additional Comments and Announcement of Public Roundtables,” May 21, 2014 (PDF)
  • AIPLA Comments on Notice of Inquiry Regarding "Strategic Plan for Recordation of Documents," March 14, 2014 (PDF)
  • AIPLA Comments on Notice of Inquiry Regarding "Technological Upgrades to Registration and Recordation Functions," May 20, 2013 (PDF)
  • AIPLA Comments Submitted Pursuant to Notice of Inquiry Regarding "Orphan Works and Mass Digitization," February 4, 2013 (PDF)
  • AIPLA Comments on Remedies for Small Copyright Claims, January 16, 2012 (PDF)
  • AIPLA Comments to DMCA Rulemaking Regarding Exemptions to Prohibition on Circumvention of Copyright Protection Systems for Access Control Technologies, submitted February 2, 2009. (PDF)
  • AIPLA Comments on the Notice of Inquiry regarding the issues raised by “orphan works," submitted May 8, 2005 (PDF – 3 pages - 39K*)
Department of Commerce
  • AIPLA Comments to the Department of Commerce Regarding Shared Services, October 2, 2017 (PDF)
  • AIPLA Comments to the Department of Commerce Regarding the Position of USPTO Director, June 28, 2017 (PDF)
  • AIPLA Post-Meeting Comments to Department of Commerce Regarding "Request for Comments on Department of Commerce Green Paper on Copyright Policy, Creativity, and Innovations in the Digital Economy," January 17, 2014 (PDF)​
Food and Drug Administration
  • AIPLA Comments on FDA Public Hearing on Facilitating Competition and Innovation in the Biological Products Workplace, September 19, 2018 (PDF)
  • AIPLA Comments on FDA Biosimilars Draft Guidances, May 24, 2012 (PDF)
  • AIPLA Comments re FDA Implementation of the Q1 Act, January 30, 2009 (PDF)
Department of Justice
  • AIPLA Comments to FTC/DOJ on the FTC/DOJ December 10, 2012, "Patent Assertion Entity Activities Workshop," April 5, 2013 (PDF)
  • ​AIPLA Response to the Antitrust Modernization Commission Regarding Questions for Public Comment on Its New Economy Study Plan (PDF – 11 pages - 67K*)
Department of State
  • AIPLA Comments on the Draft Convention on the Recognition and Enforcement of Foreign Judgments Relating to Civil or Commercial Matters, March 19, 2018 (PDF)​
  • AIPLA and PhRMA Comments on Draft Convention on the Recognition and Enforcement of Foreign Judgments Relating to Civil or Commercial Matters​ Currently Being Negotiated at The Hague Conference on Private International Law​, July 19, 2017 (PDF​)
Federal Trade Commission
  • AIPLA Comments on Competition and Consumer Protection in the 21st Century Hearings, August 20, 2018 (PDF)
  • AIPLA Comments Regarding Proposed Consent Agreement in MPHJ Technology Investments, LLC, et al., December 8, 2014 (PDF)
  • AIPLA Comments to FTC and OMB Regarding Revised PAE Study, June 18, 2014 (PDF)
  • AIPLA Comments to FTC on Section 6(b) PAE Report, December 16, 2013 (PDF)
  • AIPLA Comments to FTC/DOJ on the FTC/DOJ December 10, 2012, "Patent Assertion Entity Activities Workshop," April 5, 2013 (PDF)
  • AIPLA Comments on the Decision and Proposed Consent Order in the Google Proceeding, February 22, 2013 (PDF)
  • AIPLA Comments on the Decision and Proposed Consent Order In re Robert Bosch GmbH, FTC File No.121-0081, December 20, 2012 (PDF)
  • AIPLA Comments on Standards-Setting Issues In Connection with Patent Standards Workshop, filed June 14, 2011 (PDF)
  • AIPLA Comments on Section 5 Workshop, filed October 24, 2008 (PDF)
  • AIPLA Response to the Decision and Proposed Consent Order in the N-Data proceeding, filed April 5, 2008 (PDF)
  • AIPLA Response to the October 2003 FTC Report, Submitted April 21, 2004 (51 pages - 350K* - HERE to view the Response; Click HERE to view the FTC Report, 10/2003)
Internal Revenue Service
  • AIPLA Testimony on proposed revisions to 26 C.F.R. Parts 1 and 301, delivered February 21, 2008 before the Internal Revenue Service. (PDF)
  • AIPLA Response to the October 2007 rule proposed by the U.S. Internal Revenue Service (IRS) on “Patented Transactions,”submitted December 26, 2007 (3 pages - 37K* - Click PDF to view the Response; click HERE to view the IRS proposed rule (10/22/2007)
National Academy of Sciences
  • ​AIPLA Response to the National Research Council's Report on Reaping The Benefits of Genomic and Proteomic Research (31 pages –197K* Click HEREto view the Response; For information on the Report: Reaping the Benefits of Genomic and Proteomic Research: Intellectual Property Rights, Innovation, and Public Health, please visit The National Academies Press by clicking HERE.)
  • AIPLA Response to the National Academies Report entitled "A Patent System for the 21st Century" (49 pages–243K* Click PDF to view the Response; Click PDF to view the Report.)
National Institutes of Health
  • Comments on Draft Report to the Secretary of Health and Human Services: "Public Consultation Draft Report on Gene Patents and Licensing Practices and Their Impact on Patient Access to Genetic Tests" 74(52) Federal Register 11730 (March 19, 2009) ( PDF)
National Institute of Standards and Technology
  • AIPLA Response NIST Bayh-Dole Regulation, Dec 9, 2016 (PDF​)​
  • AIPLA Comments to the National Institute of Standards and Technology (National Science and Technology Council's Sub-Committee on Standards) on Standardization Feedback for Sub-Committee on Standards, February 18, 2011 (PDF)​
US Customs and Border Protection
  • AIPLA Comments to U.S. Customs and Border Protection on Proposed Rulemaking, "Disclosure of Information for Certain Intellectual Property Rights Enforced at the Border," June 25, 2012 (PDF)​​
US international Trade Commission
  • AIPLA Comments on Proposed Amendments to the Commission's Rules of General Application, Adjudication and Enforcement, November 23, 2015 (PDF)
  • AIPLA Comments on Commission FY2015 Budget and Space for Section 337 Investigations, May 19, 2014 (PDF)
  • AIPLA Comments to U.S. Intellectual Property Enforcement Coordinator in Response to Request for Public Comments:  "Interagency Review of Exclusion Order Enforcement Process," July 19, 2013 (PDF)
  • AIPLA Comments on "Notice of Proposed Rulemaking on Rules of General Application, Adjudication, and Enforcement,” December 4, 2012 (PDF)
  • AIPLA Comments on "Notice of Proposed Rulemaking on Rules of General Application, Adjudication, and Enforcement,” September 17, 2012 (PDF)
  • AIPLA Comments on Proposed Revisions to Rules of Practice and Procedure and Proposed Handbook on Filing Procedures, August 5, 2011 (PDF)
  • AIPLA Comments on proposed revisions to 19 C.F.R. Sections 201 and 210, filed March 19, 2008 at the US International Trade Commission (PDF)
US Securities and Exchange Commission
  • AIPLA Comments to Concept Release on Business and Financial Disclosure Required by Regulation S-K​, August 9, 2016 (PDF)​
US Trade Representative 
  • AIPLA Comments on the Draft Convention on the Recognition and Enforcement of Foreign Judgments Relating to Civil or Commercial Matters, March 19, 2018 (PDF)​
  • AIPLA and PhRMA Comments on Draft Convention on the Recognition and Enforcement of Foreign Judgments Relating to Civil or Commercial Matters​ Currently Being Negotiated at The Hague Conference on Private International Law​, July 19, 2017 (PDF)
  • AIPLA Comments on the proposed Anti-Counterfeiting Trade Agreement ("ACTA" or "Agreement") and the ongoing negotiations between the possible Member States, submitted September 27, 2010. (PDF)
  • AIPLA Comments on the Proposed Amendment and Correction of Trademark Registrations published in the Federal Register on December 18, 2003 (Comments submitted February 2, 2004) (PDF)
  • AIPLA Comments on the "Work Program set forth in the draft Ministerial Declaration submitted by the WTO General Council and WTO Director-General for consideration at the Fourth Session of the Ministerial Conference scheduled for Doha, Qatar next month" (October 11, 2001) (PDF​)
Other

Regarding the Position of the USPTO Director

  • AIPLA Comments to the Department of Commerce Regarding the Position of USPTO Director, June 28, 2017 (PDF​)
  • AIPLA White Paper Concerning the Recommended Qualifications for the Next Director and Deputy Director of the U.S. Patent and Trademark Office, November 2013 (PDF)​

​Office of the Presidential Transition

  • AIPLA Letter to President-Elect Donald Trump, Jan. 4, 2017 (PDF​​)​

U.S. Intellectual Property Enforcement Coordinator

  • AIPLA Comments to U.S. Intellectual Property Enforcement Coordinator on Development of the Joint Strategic Plan on Intellectual Property Enforcement, October 30, 2015 (PDF)​
  • AIPLA Comments to U.S. Intellectual Property Enforcement Coordinator in Response to Request for Public Comments:  "Interagency Review of Exclusion Order Enforcement Process," July 19, 2013 (PDF)
  • AIPLA Comments to OMB Regarding Negative Impact of Sequestration on USPTO Funding and Operations, May 21, 2013 (PDF)
  • AIPLA Comments to U.S. Intellectual Property Enforcement Coordinator in Response to Request for Public Comments for "Trade Secret Theft Strategy Legislative Review," April 22, 2013 (PDF)
  • AIPLA Comments to U.S. Intellectual Property Enforcement Coordinator on Development of the Joint Strategic Plan on Intellectual Property Enforcement, August 10, 2012 (PDF)​

The Sedona Conference

  • AIPLA Comments on the Sedona Conference Report on the Markman Process, submitted February 2, 2007 (PDF)
  • AIPLA Comments on the Revised April 2005 Public Comment Draft" of The Sedona Guidelines: Best Practices Addressing Protective Orders, Confidentiality & Public Access in Civil Cases (the "Draft Guidelines"). Filed May 14, 2006. (PDF)
  • Letter expressing initial concerns of AIPLA on the Revised April 2005 Public Comment Draft" of The Sedona Guidelines: Best Practices Addressing Protective Orders, Confidentiality & Public Access in Civil Cases (the "Draft Guidelines"). Filed March 10, 2006. (PDF)

Miscellaneous

  • AIPLA Joint Comments to Mayor Eric Garcetti in Support of the Anti-Piracy Unit of the Los Angeles Police Department, March 9, 2018 (PDF)