COGR Submits Comments to NIST on Draft Interagency Guidance Framework for Considering the Exercise of March In Rights

COGR, representing over 200 U.S. research institutions, submitted comments urging the withdrawal of the proposed Interagency Guidance Framework for Considering the Exercise of March-In Rights under the Bayh-Dole Act. COGR argues that the Framework, particularly its consideration of product pricing as a trigger for march-in, would undermine successful technology transfer practices, deter industry partnerships, and introduce significant uncertainty and administrative burdens, ultimately threatening innovation and U.S. competitiveness. The association further warns that vague terminology and expanded triggers for march-in could encourage frivolous challenges, harm small businesses, and jeopardize national security, counter to the objectives of the Bayh-Dole Act and key federal initiatives.