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Dear All- In addition to Georg’s comments & concerns that I support, I believe Gil’s suggested PAR-based approach, setting aside for a moment any breach in legal obligations, also places too much burden on the Working Group chairs. Gil has suggested
that WG Chairs consider asking for “new LoAs when an accepted LoA pre-dates the text of the current policy,” and cites the March 15, 2015 patent policy. To begin, I would like to remind Gil the current IEEE-SA Standards Board Bylaws, to which the Patent Policy
is located at Sect 6, is dated December 2015 that was amended since the March 2015 policy “to remove the words ‘(for the purposes of licensing information)’ from Section B of the LOA form.” (See,
http://standards.ieee.org/develop/policies/bylaws/sb_bylaws.pdf and
https://standards.ieee.org/about/sasb/resolutions.html) As a practical matter, it should also be noted, when a PAR is created, it will have “Incorporated Baselines” as noted here:
http://www.ieee802.org/11/Reports/802.11_Timelines.htm. It sounds like Gil is suggesting that the WG chairs should then seek LoAs for each of the Incorporated Baselines pertaining to a new Working Group, should the prior-accepted LoAs pre-date the text of the current patent policy. As an example, for TGax, PAR Approval date of 27 March 2014: ·
TGax has incorporated baselines of 802.11REVmc, 802.11ai, 802.11ah, 802.11aq, 802.11ak, & 802.11aj; ·
802.11REVmc has incorporated baselines 802.11-2012, 802.11ae-2012, 802.11aa-2012, 802.11ad-2012, 802.11ac-2012, & 802.11af-2013; and ·
802.11-2012 has incorporated baselines 802.11-2007, 802.11k-2008, 802.11r-2008, 802.11y-2008, 802.11w-2009, 802.11n-2009, 802.11p-2010, 802.11z-2010, 802.11v-2011, 802.11u-2011 & 802.11s-2011. So, for TGax, the WG Chair would have to seek LoAs for 21 prior incorporated baselines? Then for TGay (PAR Approval date of 26 Mar 2015), that WG Chair would have to seek 22 new LoA’s according to Gil’s PAR-based approach if a prior-accepted
LoA pre-dates the text of the current policy (Dec 2015)? And for any new Working Group created post December 2015, the chair would have to seek LoAs from 23 incorporate baselines, from my understanding of Gil’s PAR-based approach that seems not only unworkable
from a process perspective, but from a resource perspective. I look forward to seeing y’all next week. Sincerely, Jim Harlan • Director, Standards & Competition Policy • InterDigital, Inc. 515 C St NE, Washington, DC 20002 • T: +1 202-349-1713 •
Jim.Harlan@xxxxxxxxxxxxxxxx |