Comment from June Im (Senior Legal Counsel of Competition at Ericsson Inc.)

Summary: Ericsson, a global information and communication technology company, opposes the creation of an antitrust safe harbor or guidance that would shield Licensing Negotiation Groups (LNGs) from scrutiny. The company argues that LNGs are likely anticompetitive, facilitate collective holdouts, and lack proven procompetitive justifications compared to existing models like patent pools.