Comment Letter

COGR & AAU Submit Joint Comments in Response to Unlocking the Full Potential of Intellectual Property by Translating More Innovation to the Marketplace (Docket No. PTO-C-2024-004)

COGR and AAU, representing leading U.S. research universities, submitted comments to USPTO Director Kathi Vidal expressing agreement with AUTM’s positions and addressing key issues impacting university technology transfer and innovation commercialization. They voiced serious concerns about NIST's draft march-in rights framework, warning that its adoption could deter investment and harm patent licensing essential for translating research to market. The letter also emphasizes the need for clarified patent eligibility, improved PTAB practices, affordable fees for universities, international harmonization of patent law, faster and higher-quality patent examinations, enhanced patent databases, best practices for licensing biological materials and data, and targeted support for HBCUs, while commending USPTO efforts and affirming their commitment to collaborate on strengthening the U.S. intellectual property system.

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