Comment Letter

Higher Education Associations Comments to NIST

By Kevin Wozniak

A coalition of leading academic associations, including AAU, APLU, AAMC, ACE, AUTM, and COGR, submitted comments opposing the National Institute of Standards and Technology's (NIST) Draft Interagency Guidance Framework for Considering the Exercise of March-In Rights under the Bayh-Dole Act. They argue that the proposed framework introduces unnecessary ambiguity, focuses inappropriately on “reasonable pricing” as a criterion for march-in, and risks undermining established, successful technology transfer practices fundamental to U.S. innovation and economic competitiveness. The coalition urges NIST to withdraw the framework, stating it would destabilize public-private research commercialization partnerships, impede the objectives of the Bayh-Dole Act, and harm the U.S. technology transfer ecosystem.

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Author

Kevin Wozniak

Kevin Wozniak is the Director of Research Security & Intellectual Property at COGR.