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Comment Letter

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...

Policy Perspective

Technology Transfer in U.S. Research Universities: Dispelling Common Myths (Updated August 2022)

This document, published by COGR, systematically addresses and dispels common misconceptions about technology transfer activities within U.S. research universities...

Resources

Policy Perspective 05 Nov, 2025

Material Transfer in Academia: 20 Questions and Answers (2021 Update)

The document provides a comprehensive overview of material transfer agreements (MTAs) in academic research, emphasizing their critical role in regulating the exchange of research materials—especially in the life sciences—and addressing complex issues such as ownership rights, academic freedom,…

Event Materials 24 Oct, 2025

Committee Reports—October 2025 Meeting

The October 24, 2025 Committee Reports & Hot Topics document from the four standing COGR Committees outlines recent and ongoing activities across its four main committees: Contracts & Grants Administration (CGA), Research Ethics & Compliance (REC), Research Security & Intellectual Property (RSIP)...

Event Materials 23 Oct, 2025

Navigating the Storm 2.0: Institutional Perspectives on a Changing Federal Landscape—October 2025

The document outlines the agenda and discussion framework for “Navigating the Storm 2.0: Institutional Perspectives on a Changing Federal Landscape,” a session held by COGR on October 24, 2025. The event features COGR directors leading table discussions on pressing topics such as research…

COGR Update 26 Sep, 2025

COGR’s September 2025 Update

The September 2025 COGR Update provides an overview of recent federal developments affecting U.S. research institutions, including proposed regulatory changes, executive orders, litigation updates, and agency-specific policy shifts impacting research funding, compliance, security, and administration...

Event Materials 05 Jun, 2025

Exploring University-Industry Collaborations at a Pivotal Moment: A Historical Insight and Potential Future Directions: June 2025 COGR Meeting

This document discusses the evolving landscape of university-industry collaborations, emphasizing the need for modernization and increased impact in light of challenges such as declining U.S. R&D leadership, funding gaps, and workforce needs. It highlights initiatives by UIDP and Georgia…

Event Materials 05 Jun, 2025

Navigating the Storm: Institutional Perspectives on a Changing Federal Landscape: June 2025 COGR Meeting

The document summarizes a COGR (Council on Governmental Relations) session titled "Navigating the Storm: Institutional Perspectives on a Changing Federal Landscape," held on June 6, 2025. The agenda was structured to facilitate collaborative discussions among institutional representatives on the…

COGR Update 16 May, 2025

May 2025 COGR Update

The May 2025 COGR Update provides an overview of recent federal policy changes, regulatory actions, and litigation that are significantly reshaping research administration and compliance. COGR highlights challenges posed by new indirect cost caps, increased regulatory and reporting burdens,…

COGR Update 21 Mar, 2025

March 2025 Update

The March 2025 COGR Update provides an overview of the complex and rapidly changing federal research environment, detailing the significant impact of recent policy shifts, executive orders, and administrative actions on research institutions. It highlights escalating regulatory burdens, funding…

Comment Letter 21 Feb, 2025

COGR Responds to NSF RFC on Proposed Intellectual Property Options

COGR submitted a response to the National Science Foundation’s (NSF) request for comments regarding proposed new intellectual property (IP) frameworks for public-private partnerships, expressing concern that prescribed, inflexible IP terms could hinder successful technology transfer and…

COGR Update 14 Feb, 2025

COGR February 2025 Update

The February 2025 COGR Update provides a detailed account of significant regulatory, policy, and administrative changes impacting U.S. research institutions, driven largely by executive orders from the Administration that restrict DEI programs, roll back regulations, and alter research funding…

Comment Letter 27 Nov, 2024

COGR Responds to USDOJ’s Notice of Proposed Rulemaking—Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons

COGR, representing over 220 U.S. research institutions, submitted comments on the Department of Justice’s proposed rule aimed at restricting access to U.S. sensitive personal and government-related data by countries of concern. COGR expresses concern that the rule’s lack of exemptions for non…

Comment Letter 22 Jul, 2024

COGR Submits Comments to NIH on Intramural Research Program Policy: Promoting Equity Through Access Planning

COGR responds to the NIH’s draft policy requiring licensees of NIH technologies to submit access plans aimed at promoting patient access, expressing support for the aim of equity but cautioning that such requirements may unintentionally complicate technology commercialization and deter potential…

Event Materials 06 Jun, 2024

Great Minds: Brainstorming & Benchmarking with COGR Member Institutions: June 2024

The document outlines the agenda and discussion themes for the "Great Minds: Brainstorming & Benchmarking" session held COGR on June 6, 2024. Moderated by key COGR directors and committee chairs from prominent research institutions, the session provides a collaborative platform for member…

Comment Letter 17 May, 2024

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…

Event Materials 01 Mar, 2024

Federal March In Provisions & NIST Draft Framework: February 2024 Meeting

COGR's virtual meeting held from February 27 to March 1, 2024, featured expert discussions on federal policies affecting university technology transfer, focusing particularly on the National Institute of Standards and Technology (NIST) draft framework regarding march-in rights under the Bayh…

Event Materials 27 Feb, 2024

Biden EO on AI: Agencies Perspectives: February 2024 Meeting

The COGR virtual meeting held on February 27–March 1, 2024 focused on the Biden Administration’s Executive Order 14110 regarding artificial intelligence (AI), examining how federal agencies such as NIST and HHS are responding to its directives, and what challenges and opportunities lie ahead. The…

Comment Letter 02 Feb, 2024

Higher Education Associations Comments to NIST

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…

Comment Letter 01 Feb, 2024

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…

Comment Letter 21 Dec, 2023

COGR Joins a Multi-Association Extension Request to NIST for the RFI Regarding the Draft Interagency Guidance Framework for Considering the Exercise of March-In Rights (Docket No.: 230831-0207)

The letter, sent by major associations representing research universities and medical colleges, requests a 90-day extension to the public comment period on the National Institute of Standards and Technology's draft interagency guidance framework regarding the exercise of march-in rights under…

Comment Letter 05 Dec, 2023

COGR Joins C4IP in Urging the Biden Administration to Oppose the Proposed WTO IP Waiver for Covid-19 Therapeutics and Diagnostics

The letter, dated December 4, 2023, is addressed to President Joseph R. Biden by the Council for Innovation Promotion, a bipartisan group comprised of former senior government officials, university technology transfer experts, and leaders from trade and health sectors. The signatories urge…

Comment Letter 05 Jul, 2023

COGR Submits Joint Association Response to OMB on Comment Request; iEdison System

The letter, submitted by COGR and other higher education associations, expresses strong support for the continued redesign, expansion, and harmonization of the iEdison invention reporting system across all federal agencies, as outlined in OMB…

Archived 05 May, 2023

COGR, AAU, and AUTM Submit Joint Association Letter on COVID-19 Diagnostics and Therapeutics: Supply, Demand, and TRIPS Agreement Flexibilities

The letter, submitted jointly by the Association of American Universities (AAU), the Council on Government Relations (COGR), and AUTM, addresses the U.S. International Trade Commission in relation to Investigation No. 332-596, focusing on COVID-19 diagnostics, therapeutics, and the possible…

Policy Perspective 02 Aug, 2022

Technology Transfer in U.S. Research Universities: Dispelling Common Myths (Updated August 2022)

This document, published by COGR, systematically addresses and dispels common misconceptions about technology transfer activities within U.S. research universities. It presents evidence and expert analysis to refute the belief that such activities detract from universities' core missions,…

Event Materials 25 May, 2022

October 23-24, 2025 COGR Meeting Materials

Slide presentations shared during the October 23-24, 2025 COGR meeting in Washington D.C.

Event Materials 25 May, 2022

October 23-24, 2025 COGR Meeting Materials

Slide presentations shared during the October 23-24, 2025 COGR meeting in Washington D.C.

Event Materials 25 May, 2022

October 23-24, 2025 COGR Meeting Materials

Slide presentations shared during the October 23-24, 2025 COGR meeting in Washington D.C.

Event Materials 25 May, 2022

October 23-24, 2025 COGR Meeting Materials

Slide presentations shared during the October 23-24, 2025 COGR meeting in Washington D.C.

Event Materials 25 May, 2022

October 23-24, 2025 COGR Meeting Materials

Slide presentations shared during the October 23-24, 2025 COGR meeting in Washington D.C.

Event Materials 25 May, 2022

October 23-24, 2025 COGR Meeting Materials

Slide presentations shared during the October 23-24, 2025 COGR meeting in Washington D.C.

Event Materials 25 May, 2022

October 23-24, 2025 COGR Meeting Materials

Slide presentations shared during the October 23-24, 2025 COGR meeting in Washington D.C.

Policy Perspective 14 Oct, 2021

The Bayh-Dole Act A GUIDE TO THE LAW AND IMPLEMENTING REGULATIONS

The Bayh-Dole Act, enacted in 1980 and subsequently amended, established a uniform federal policy allowing universities and small businesses to retain ownership of inventions developed through federally funded research, thereby facilitating technology transfer to the private sector and fostering…

Policy Perspective 06 Oct, 2021

Tech Transfer Tutorial V3

This document provides a detailed overview of technology transfer practices in U.S. colleges and universities, emphasizing the role of research institutions in advancing economic development through the formal commercialization of intellectual property. It explains the foundational legal, policy…

Comment Letter 26 Aug, 2021

COGR Submits Joint Comments with AUTM and Bayh-Dole Coalition to DOE on Exceptional Circumstances Determination

The letter addresses concerns from the Bayh-Dole Coalition and allied organizations regarding the U.S. Department of Energy’s (DOE) recent “determination of exceptional circumstances” (DEC), which aims to promote domestic development of DOE-funded inventions. While the coalition appreciates the DOE…

Policy Perspective 24 Aug, 2021

COGR’s Releases Paper on “Foreign Influence—Practical Considerations in Developing an Institutional Response”

This document outlines the increasing federal scrutiny on inappropriate foreign influence in U.S. academic research and offers practical considerations for institutions to develop effective research security responses. Triggered by concerns such as undisclosed foreign funding, participation in…

Comment Letter 14 Jul, 2021

COGR, AAU, and APLU Submit Letter to DOE on Order 142.3B

This letter sets forth comments to the Dept. of Energy from COGR, Association of American Universities (AAU), and Association of Public and Land-grant Universities (APLU) regarding the application of DOE Order 142.3B and the removal of the limited screening exemption for U.S. universities

Policy Perspective 07 Jun, 2021

Materials Transfer in Academia: 20 Questions and Answers

The document "Materials Transfer in Academia: 20 Questions and Answers" (2021), published by the Council on Governmental Relations (COGR), provides a detailed overview of the complexities and best practices associated with materials transfer agreements (MTAs) within academic research. It outlines…

Comment Letter 05 Apr, 2021

Joint Association Comments on NIST NPRM Proposed Changes to Part 401 and 404

This letter provides association comments regarding changes proposed to Part 401 Rights to Inventions Made by Nonprofit Organizations and Small Business Firms Under Government Grants Contracts and Cooperative Agreements.

Comment Letter 23 Feb, 2021

COGR Joins Multi Association Comment Letter on the National Strategy for Expanding American Innovation (Docket #PTO-P-2020-0057)

The document presents joint comments from four major academic and research organizations regarding the USPTO’s National Strategy for Expanding American Innovation. The associations express strong support for the strategy and the principles shared by their peer organizations. They emphasize the…

Event Materials 26 Oct, 2020

Research Security and Intellectual Property Hot Topics: October 2020 Meeting

The document is a comprehensive overview of key issues on research security and intellectual property management discussed during a panel convened by the Council on Governmental Relations (COGR) on October 22, 2020, featuring experts from leading research universities. The panelists addressed…

Event Materials 03 Mar, 2020

RSIP Committee Report: March 2020 Meeting

The document provides an update on several key initiatives and regulatory changes impacting research security and intellectual property management, primarily within the context of federally funded research in the United States. It outlines the ongoing redevelopment of the iEdison system, which…

Event Materials 10 Jun, 2019

Contracts & Intellectual Property Update: June 2019 Meeting

The document outlines recent developments and ongoing discussions concerning contracts and intellectual property at U.S. academic and research institutions, with a particular focus on the influence of foreign entities. It details the increasing scrutiny from legislative and federal agencies…

Policy Perspective 21 Mar, 2019

Questions for Section 101 Roundtable Participants

The document presents the views of the Association of American Universities (AAU), Association of Public and Land-grant Universities (APLU), and Council on Governmental Relations (COGR) regarding potential reforms to Section 101 of U.S. patent law. These organizations emphasize the critical role of…

Event Materials 05 Nov, 2018

Control of Licensing Subgroup Presentation

The document outlines key themes discussed by the Control of Licensing Subgroup, focusing on the balance between control and communication in the context of licensing agreements. It distinguishes considerations before and after a license is granted. Pre-license factors include developing a…

Survey 18 Jul, 2018

Intellectual Property and Technology Transfer Group Report-Out (NFRI)

The Intellectual Property and Technology Transfer Group conducted a survey and breakout discussion to assess the prevalence and negotiation dynamics of various IP provisions in research agreements. Survey responses, representing both funding (27.5%) and performing (72.5%) entities, indicated that…

Survey 18 Jul, 2018

Results of Intellectual Property and Technology Transfer Sub-group Survey (NFRI)

The Intellectual Property and Technology Transfer Sub-group Survey, conducted on May 14, 2018, gathered input from forty respondents representing both research funding and research-performing entities. The survey explored a wide spectrum of issues pertinent to IP management and technology transfer…

Policy Perspective 18 Jul, 2018

Intellectual Property & Technology Transfer (NFRI)

The document outlines the purpose, goals, and preliminary findings of the Sub-group on Intellectual Property (IP) and Technology Transfer, comprising representatives from various universities, research institutions, and foundations. This group seeks to enhance collaboration and streamline processes…

Event Materials 12 Jun, 2018

Unleashing American Innovation: June 2018 Meeting

The document, presented by Walter G. Copan, Under Secretary of Commerce for Standards and Technology and Director of the National Institute of Standards and Technology (NIST), outlines the role of NIST in advancing U.S. innovation, economic security, and quality of life through leadership in…

Event Materials 26 Feb, 2018

The Academia-Industry-Government Innovation Cycle: February 2018 Meeting

The document, delivered by Jeannette M. Wing at the Council on Governmental Relations, explores the critical and intertwined roles that academia, industry, and government play in driving innovation, particularly in the realm of information technology. Using historical developments and major market…

Event Materials 26 Feb, 2018

The EU GDPR: Implications for U.S. Universities and Academic Medical Centers: February 2018 Meeting

This document provides a thorough analysis of the European Union’s General Data Protection Regulation (GDPR) and its implications for U.S. universities and academic medical centers (AMCs). With the GDPR’s enforcement from May 25, 2018, data privacy requirements have become more stringent and…

Archived 17 Jul, 2017

COGR Submits Joint Association Letter on DOE Regulatory Reform

This letter provides joint association comments on Department of Energy regulations, paperwork requirements and other regulatory obligations as part of the agency’s implementation of Executive Order 13771, “Reducing Regulation and Controlling Regulatory Costs.”

Event Materials 13 Jun, 2017

June 2017 Presentation: UIDP Updates

The document provides an overview of the University-Industry Demonstration Partnership (UIDP), emphasizing the contemporary significance of industry engagement in academic research and development (R&D). Citing 2013 NSF data, it notes that federal sources still constitute the majority (57%) of US…

Archived 08 Aug, 2016

COGR Testimony at NIH Hearings on March-in Rights

NIH has denied the request from Essential Inventions, Inc. to exercise march-in rights under The Bayh-Dole Act in connection with the pricing of Norvir, marketed by Abbott Laboratories for the treatment of patients with HIV/AIDS. The decision and related materials are available online. Andrew...

Archived 08 Aug, 2016

COGR Testimony at NIH Hearings on March-in Rights

NIH has denied the request from Essential Inventions, Inc. to exercise march-in rights under The Bayh-Dole Act in connection with the pricing of Norvir, marketed by Abbott Laboratories for the treatment of patients with HIV/AIDS. The decision and related materials are available online. Andrew...

Comment Letter 08 Aug, 2016

March-in Rights Under Bayh-Dole

COGR sent comments on march-in rights under the Bayh-Dole Act to the Office of Technology Transfer at the National Institutes of Health.

Policy Perspective 08 Aug, 2016

The Bayh-Dole Act: A Guide to the Law and Implementing Regulations (October 2021 Update)

Originally published in 1999, and updated October 2021: Contributors: COGR would like to thank the Research Security & Intellectual Property Management Committee (RSIP), and in particular, Michael Moore from Augusta University, for contributing to the update of this paper, originally published in...

All Intellectual Property & Innovation Articles