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RE: [PP-DIALOG] Reciprocity clause needed



It seems there is discrepancy that others consider reciprocity
otherwise. That in itself supports the need to make reciprocity explicit
part of the LOA. I agree with Hung that a reciprocity box is needed to
ensure equities, fairness, to avoid manipulation and provide clarity.
The LOA is a facilitating statement patent holders make to the public.
IEEE cannot dictate what those licenses are or what the public statement
is in the words of the patent holder, but it should be clear to users
that reciprocity is expected as a condition on the irrevocable offer to
license, when it is.  

Michelle


-----Original Message-----
From: Chuck AdamsJr [mailto:wcadams@US.IBM.COM] 
Sent: Friday, March 17, 2006 10:21 AM
To: PP-DIALOG@listserv.ieee.org
Subject: Re: [PP-DIALOG] Reciprocity clause needed


Hung, you raise an interesting question regarding reciprocity and
suspension terms.  I do not believe that you will find an argument that
reciprocity and suspension can be considered reasonable terms.  Several
years ago the SA's LOA contained a paragraph indicating that reciprocity
and suspension were reasonable.   However, a challenge was raised
referencing the IEEE-SA policy of not addressing nor promoting
licensing terms through its LOA process.  Consequently this terminology
was removed from the LOA, with the assumption that determining
reasonable terms would be between the parties involved in the licensing
process, as long as the terms were not discriminatory..

Chuck Adams
Program Director of Standards & Open Source Technology,Intellectual
Property,Open Source,Standards IBM Corporation North Castle Drive,
Armonk, New York,10504

(914)-765-4382 [Internal 8/251-4382] Fax (914)-765-4420
Internet: WCADAMS@US.IBM.COM
http://w3.ibm.com/standards http://www.ibm.com/ibm/licensing/standards


 

             "Ling, Hung C

             (Hung)"

             <hling@LUCENT.COM
To 
             >                         PP-DIALOG@listserv.ieee.org

 
cc 
             03/17/2006 08:12

             AM
Subject 
                                       Re: [PP-DIALOG] Reciprocity
clause  
                                       needed

             Please respond to

               "Ling, Hung C

                  (Hung)"

 

 

 





Mike, Don and All:

There has been good discussion on Box 2C in the last few days.   (Sorry
I
was out of commission for the past few days.)  It is also not clear to
me why this box is needed.

In my original email starting this thread on reciprocity, I used Box 2C
as an hypothetical example to illustrate the case why  a reciprocity
clause (and may be defense suspension) is needed.  I did not mean to
restrict my comment to that box only.

The need equally applies to Box 2B or any other box.  If one is willing
to license on RAND its essential patent claims, that entity should be
protected by reciprocity so that any implementer or third party cannot
come back and ask for more-than-RAND terms on their own essential patent
claims (should they hold any).  Thus, explicitly allowing for
reciprocity would greatly help the situation.

I, therefore, specifically disagreed with Dennis Brophy's statement that
"My position is they would have to pay."

Hung Ling
      -----Original Message-----
      From: Sirtori, Michael J [mailto:michael.j.sirtori@INTEL.COM]
      Sent: Tuesday, March 14, 2006 10:22 PM
      To: PP-DIALOG@listserv.ieee.org
      Subject: Re: [PP-DIALOG] Reciprocity clause needed

      Thanks Don,

      I agree that explicitly allowing for reciprocity and defensive
      suspension might help, but that sort of undermines the "without
      conditions" aspect, which seems to be the main desire for creating
      this check box in the first place.

      Personally I would propose streamlining the form by deleting this
      check box 2C altogether.  Anyone who owns a patent and for
whatever
      reason doesn't want to assert any royalties can simply check box A
      "license without compensation".  That is probably good enough for
      99.9% of the cases, and I am confident that no one will come
knocking
      on the patent holder's door asking for a definitive royalty free
      license.

      -Mike


      From: don@lexmark.com [mailto:don@lexmark.com]
      Sent: Tuesday, March 14, 2006 3:30 PM
      To: Sirtori, Michael J
      Cc: PP-DIALOG@listserv.ieee.org
      Subject: RE: [PP-DIALOG] Reciprocity clause needed


      Michael:

      If memory serves, that box has not existed on the LOA form for a
long
      period of time so there's minimal history to guide us but we can
      look.  I do share your concerned about the wisdom of someone
checking
      the blanket LOA box except in some very specific circumstances
such
      as you describe.  I suppose a patent holder who doesn't want to
      create and manage licenses for such a patent claim would also be a
      potential user of this option.

      Do you think it would be better to explicitly allow for
reciprocity
      and defensive suspension rather than saying "without condition" or
      adding yet another check box?

 
************************************************************************
***

       Don Wright                      don@lexmark.com
                                       f.wright@ieee.org /
      f.wright@computer.org
       Director of Standards
       Lexmark International           Past Chair, IEEE SA Standards
Board
       740 New Circle Rd               Chair, Patent Committee IEEE SASB
       Lexington, Ky 40550             Member-at-large, IEEE CS SAB
       859-825-4808 (phone)            Member, IEEE-ISTO Board of
Directors

       603-963-8352 (fax)              Member, W3C Advisory Committee
 
************************************************************************
***







 

   "Sirtori, Michael J"

   <michael.j.sirtori@intel.com>             To:

   Sent by: PP-DIALOG@ieee.org       <PP-DIALOG@listserv.ieee.org>

                                             cc:

                                             Subject:        RE:

   03/14/2006 06:15 PM               [PP-DIALOG] Reciprocity clause

                                     needed

 






      Thanks Dennis and Hung.

      I share Hung's concern that if a company checks box Box 2c ("The
      Patent Holder without conditions will not enforce any of its ...
      patents") it is potentially putting itself in a very dangerous
      position, as it likely no longer be able to use the relevant
patents
      to defend itself.

      And I agree with Dennis that if a company wants to reserve any
      rights, it should not check that box.  I also agree that few
      commercial entities would want to, or be advised to, check the
      "without conditions will not enforce" box.  I doubt many of the
legal
      advisors on this reflector will ever advise their clients to check
      that box.

      So why does that box even exist?  Is it for altruistic patent
      holders, or inventors with no commercial interests?  I am not
opposed
      to that, but do we really think it is worth keeping, in light of
the
      confusion it causes?

      Don, it might be worthwhile and informative for the PatCom to know
      how many times over the past few years any submitter has checked
that
      box.  Does IEEE staff retain that information?

      Thanks.
      -Mike




      From: Brophy, Dennis [mailto:dennisb@MODEL.COM]
      Sent: Friday, March 10, 2006 9:50 PM
      To: PP-DIALOG@listserv.ieee.org
      Subject: Re: [PP-DIALOG] Reciprocity clause needed

      Hung Ling,

        My position is they would have to pay.  There are issues with
      standards development that one participant could mine a standard
with
      the IPR of another and in effect scuttle that standard.  There is
      also a specific lack of reciprocity in today's LOA which could
merit
      discussion.  Maybe there could be something added to the front
mater
      of each standard where license for use is granted.

        If you want to hold ALL threats in abeyance, this might work:

      If a Party institutes patent litigation against a party who has
      submitted an LOA (LOA Party) with respect to a patent (including a
      cross-claim, counterclaim or declaratory judgment claim in a
      lawsuit), then any patent licenses granted by that LOA Party to
such
      Party under the LOA shall terminate as of the date such litigation
is
      filed. In addition, if Party institutes patent litigation against
any
      entity (including a cross-claim, counterclaim or declaratory
judgment
      claim in a lawsuit) alleging that the Standard itself (excluding
      combinations of the Standard with other software or hardware)
      infringes such Party's patent(s), then the rights granted to Party
by
      the IEEE shall terminate as of the date such litigation is filed.

        If you want to hold only threats related to the specific
standard
      in abeyance, this might work:

      If a Party institutes patent litigation against a party who has
      submitted an LOA (LOA Party) with respect to a patent applicable
to
      the Standard (including a cross-claim, counterclaim or declaratory
      judgment claim in a lawsuit), then any patent licenses granted by
      that LOA Party to such Party under the LOA shall terminate as of
the
      date such litigation is filed.  In addition, if Party institutes
      patent litigation against any entity (including a cross-claim,
      counterclaim or declaratory judgment claim in a lawsuit) alleging
      that the Standard itself (excluding combinations of the Standard
with
      other software or hardware) infringes such Party's patent(s), then
      the rights granted to the Party by the IEEE shall terminate as of
the
      date such litigation is filed.
        I don't think the IEEE wishes to see its standards held hostage
or
      mined with other's IPR.  And since entities will probably want to
      reserve as many rights to themselves, one could predict that few
if
      any would want to, or be advised to, check the "without
conditions"
      terms.  However, I think entities that come together and do just
      demonstrate how they hold standards in high esteem and value.

      -Dennis



      From: Ling, Hung C (Hung) [mailto:hling@LUCENT.COM]
      Sent: Friday, March 10, 2006 1:36 PM
      To: PP-DIALOG@listserv.ieee.org
      Subject: Re: [PP-DIALOG] Reciprocity clause needed
      Don has said on a number of occasions that the LoA should be
binding
      on the patent holder (who submits it) to any third party
      beneficiaries.

      If I may, let me put you into a hypothetical scenerio.  You are an
      IEEE participant representing company A that has submitted a LoA
on
      an essential patent claim that you are aware of, and has checked
off
      Box 2 C (The Patent Holder without conditions will not enforce any
of
      its ... patents .....).  Along comes a third party B with its own
      essential claim on the same standard.  Let's assume party B did
not
      participate in IEEE standards activitiy and hence has not
submitted a
      LoA.  Should Company A honor its LoA by granting a "free" license
to
      Party B while at the same time, pay a royalty fee to Party B?
This
      is not an equitable situation for Company A or for an individual
      patent holder to be in.  Thus, a box for checking off "reciprocity
      required" seems to be reasonable, and mostly likely a "must" for
many
      companies.

      I am interested in hearing the views of PatCom members, including
Don
      of course.

      Hung Ling
      -----Original Message-----
      From: Don Wright [mailto:don@LEXMARK.COM]
      Sent: Wednesday, February 08, 2006 2:34 PM
      To: PP-DIALOG@listserv.ieee.org
      Subject: [PP-DIALOG] An LOA draft addressing some but not all
issues
      on the table at PatCom

      PatCom Interested Parties:

      Attached, please find a draft of the LOA addressing a number of
the
      issues on the PatCom agenda and incorporating many of the ideas
and
      comments that were provided at the September 2005 and December
2005
      PatCom meetings.  Admittedly, this draft does not include proposed
      language to address all the issues on the table.  For example, we
      have excluded:

      a. the definition of reasonable rates, terms and conditions
      b. the application of LoA to amendments and revisions
      c. mandatory (or optional) inclusion of not-to-exceed royalty
rates.


      We have:

      1)   provided an expanded definition of "essential patent claim".
We
      have bracketed language about whether an essential patent claim
      should include/exclude continuations in part and are interested in
      your thoughts.

      2)   taken the 5 different licensing statements in the current
form
      and grouped them into two parts in Section D.  Either the Patent
      Holder is not aware of any essential patent claims (Box 1) or the
      Patent Holder "may" have essential patent claims (Box 2).

      With respect to Box 1, we have expanded on the Patent Holder's
      knowledge of any Essential Patent Claims which is currently
captured
      in the fifth licensing statement on the current form.  The fifth
      statement provides "I am not aware of any [Essential Patent
Claims"
      which contemplates that the signer of the form is the "I" and has
the
      relevant knowledge.  Several attendees at the December PatCom
meeting
      suggested that we should separate "knowledge" regarding essential
      patent claims from the knowledge of the authorized signer of the
LoA.
      We have used the ABA's proposed definition of "Organizational
      Knowledge" but have bracketed language regarding the knowledge of
      person responsible for the patent portfolio which is included in
the
      ABA's proposed definition of "Organizational Knowledge" but we are
      interested in your thoughts.

      With respect to Box 2, we have offered Patent Holders three
assurance
      options which are currently reflected in the first, second and
fourth
      licensing statements on the current form:  RF, RAND, or the Patent
      Holder won't enforce.  We have also given the Patent Holder the
      option of saying that it is unwilling to provide any of the
foregoing
      assurances which was formerly in third licensing statement in the
      current LoA.

      3)    noted that currently the LoA appears to be an all or nothing
      form, i.e., the current form doesn't anticipate that a Patent
Holder
      may be willing to agree to different licensing statements for
      different Essential Patent Claims.  Thus, we have added a note to
the
      LoA to make it clear that a Patent Holder may provide a different
      assurance for a specific Essential Patent Claim by submitting a
      separate LoA for such claim provided there isn't a blanket
assurance
      on file (see definition below) and there isn't a prior LoA on file
      covering the same claim.

      4)   clarified that a Patent Holder does not need to do a patent
      search and "may, but is not required to" list specific Essential
      Patent Claims.

      5)   given Patent Holders the ability to check a box indicating
that
      the LoA is a Blanket Assurance, i.e., all Essential patent Claims
      that the Patent Holder may currently or in the future hold or
control
      or otherwise have the right to license shall be available under
the
      terms described above provided the Blanket Assurance can't
supersede
      any pre-existing or simultaneously submitted assurance identifying
a
      specific Essential Patent Claims.

      6)   noted that the current LoA does not apply to a Patent
Holder's
      Affiliates.  In the last discussion draft, we gave the Patent
Holder
      the opportunity to indicate whether or not the LoA applied to its
      Affiliates.  Some have suggested that the LoA should apply to
      Affiliates at the Patent Holder's option, some have suggested that
      the LoA should apply by default to Affiliates unless the Patent
      Holder explicitly excluded its Affiliates and some have suggested
      that no Patent Holder should have the ability to exclude an
      Affiliate.  This draft proposes that the LoA applies by default to
an
      Affiliate unless the Patent Holder explicitly excludes its
      Affiliates.  We are interested in your feedback.  We have also
      incorporated the ABA's proposed definition of Affiliate --
although
      we have broadened to include control over nonprofit affiliates
which
      isn't currently captured in the ABA's proposed definition.

      7)   remembered that in the last draft we discussed in March that
the
      Patent Holder represent that the terms of the LoA would be binding
on
      any assignee or transferee of specific Essential Patent Claims
      referenced in the LoA and that the Patent Holder would notify
IEEE-SA
      of any assignment and notify the assignee or transferee of the
      existence of the commitments.   Many of you raised concerns about
      having to ensure that the LoA would be binding on
      assignees/transferees and having to notify the IEEE.  Some
suggested
      that in the alternative, we get a commitment from the Patent
Holder
      that it would not transfer any rights in any Essential Patent
Claims
      that is inconsistent with the commitments made in the LoA and that
      the Patent Holder should notify any transferee of the commitments
in
      the Letter and shall obtain the commitment of such transferee to
      notify any subsequent transferee of the commitment.  However, we
have
      clarified that the Pate! nt Holder's sole responsibility is to
      provide Notice and that the Patent Holder won't be liable for the
      failure of any subsequent assignee to honor the assurances made in
      the LoA.

      8)   made it clear that this is a binding agreement.  Implementers
of
      the standard are third party beneficiaries with rights of
      enforcement.

      We have also attached a comparison of this draft with the existing
      LOA.

      Any comments about this draft should be sent to the pp-dialog
mailing
      list.  We especially welcome comments about the high level
concepts
      being included but will also accept comments about specific choice
of
      words, grammar, etc.  Don't wait until the meeting to speak up
      because "silence equals agreement."

      Once we conclude the discussion on these topics, PatCom can then
      consider which, if any, might require an update to the IEEE SASB
      Bylaws or Operations Manual.









 
************************************************************************
***

      Don Wright                      don@lexmark.com
                                      f.wright@ieee.org /
      f.wright@computer.org
      Director of Standards
      Lexmark International           Past Chair, IEEE SA Standards
Board
      740 New Circle Rd               Chair, Patent Committee IEEE SASB
      Lexington, Ky 40550             Member-at-large, IEEE CS SAB
      859-825-4808 (phone)            Member, IEEE-ISTO Board of
Directors
      603-963-8352 (fax)              Member, W3C Advisory Committee
 
************************************************************************
***