Hello,
I provide on behalf of Nokia the following comments on the FAQ revisions.
Nokia generally supports the addition of both new proposed FAQs to the FAQ document, provided minor changes are made.
We support the first proposed FAQ but with the following clarifying addition in the first sentence of the second paragraph (as proposed by Glenn Parsons during the PatCom March 28 discussion and via PPDialog immediately afterwards): “Under the IEEE SA
Patent Policy that took effect 1 January 2023, the Submitter ….” As Glenn explained, there have been multiple versions of the Patent Policy and the FAQ as written would apply only to the current version.
With regard to the second proposed FAQ, we fail to see any strong reason for its inclusion in the document given that it seems to just state an obvious truth and does not add to an understanding of the Patent Policy. But if PatCom wishes to add this new
FAQ, we would support the second proposed FAQ if two changes are made. First, if the phrase in the first sentence of the answer is changed from “for any number of reasons” to “for any reason”. While Glenn correctly suggested in his PPDialog comments that
the original wording might imply that there have to be a few reasons together in order to update the policy, we think the original phrasing could also be misread to suggest incorrectly that there exists somewhere a limited list of enumerated reasons that must
be invoked to change the Patent Policy. Second, we think a suggestion from Brian Dorini is also helpful and should be included. Specifically, this language should be added to the end of the FAQ answer: ", or that the previous text needed to be substantively
changed". As Brian pointed out, this will reflect the fact that updates to the patent policy could indeed be substantive, and not merely administrative as suggested by the current listed examples.
Thank you,
John Kolakowski
John Kolakowski
Preferred pronouns: he/him
Director, Patent Licensing
Nokia Technologies
Contact number: +1 202-468-4428
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Preferred pronouns: he/him
Director, Patent Licensing
Nokia Technologies
Contact number: +1 202-468-4428
At Nokia, we create technology that helps the world act together.