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Comments to OMB and FTC on Patent Assertion Entity Study

June 19, 2014 ,

In the Office of Management and Budget
and the Federal Trade Commission

In the Matter of:
Agency Information Collection Activities;
Submission for OMB Review; Comment Request
PAE Reports: Paperwork Comment; Project No. P131203
ICR Reference No. 201405-3084-002

Comments of Public Knowledge

Public Knowledge respectfully submits the following comments on the proposed Patent Assertion Entity study, in response to the Notice and Comment Request dated May 19, 2014 (hereinafter “Notice”). Public Knowledge previously submitted comments on this subject matter in response to an earlier request for comments.

In brief, Public Knowledge supports the proposed study, which will appropriately benefit the public and advance the mission of the Federal Trade Commission while minimizing the paperwork burden on those from whom information is being collected. The proposed study thus both complies with the purposes of the Paperwork Reduction Act and advances valuable policy goals. This is so for at least three reasons, explained in detail below. First, the estimated cost burden is minimal and reasonable, particularly in comparison with other approved FTC studies. Second, the data to be collected will create a substantial public benefit by revealing information on a significant but secretive industry of patent assertion. Third, the proposed study would advance the mission of the FTC in protecting consumers from unfair and deceptive trade practices.

Accordingly, we commend the FTC in continuing to move forward with the proposed study on patent assertion entities, and urge OMB to approve the proposed study.