Comment from Brian Scarpelli (Senior Global Policy Counsel at the Association for Competitive Technology)

Summary: The Association for Competitive Technology (ACT), Engine, High Tech Inventors Alliance (HTIA), and Save Our Standards (SOS) support the DOJ and FTC's effort to provide clear and predictable guidance on business collaborations. However, they specifically recommend that the agencies maintain the original scope of the guidelines and avoid extending them to include standard setting and intellectual property licensing matters.