[House Hearing, 118 Congress]
[From the U.S. Government Publishing Office]






                                
 
                IP AND STRATEGIC COMPETITION WITH CHINA:
                PART IV_PATENTS, STANDARDS, AND LAWFARE

=======================================================================

                                HEARING

                               BEFORE THE

    SUBCOMMITTEE ON COURTS, INTELLECTUAL PROPERTY, AND THE INTERNET

                                 OF THE

                       COMMITTEE ON THE JUDICIARY

                     U.S. HOUSE OF REPRESENTATIVES

                    ONE HUNDRED EIGHTEENTH CONGRESS

                             SECOND SESSION

                               __________

                      WEDNESDAY, DECEMBER 18, 2024

                               __________

                           Serial No. 118-105

                               __________

         Printed for the use of the Committee on the Judiciary
         
         
         GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT
 


               Available via: http://judiciary.house.gov
               
               
               
                            _______

             U.S. GOVERNMENT PUBLISHING OFFICE 
 57-831              WASHINGTON : 2025    
               
               
               
               
               
               
               
                       COMMITTEE ON THE JUDICIARY

                        JIM JORDAN, Ohio, Chair

DARRELL ISSA, California             JERROLD NADLER, New York, Ranking 
ANDY BIGGS, Arizona                      Member
TOM McCLINTOCK, California           ZOE LOFGREN, California
TOM TIFFANY, Wisconsin               STEVE COHEN, Tennessee
THOMAS MASSIE, Kentucky              HENRY C. ``HANK'' JOHNSON, Jr., 
CHIP ROY, Texas                          Georgia
DAN BISHOP, North Carolina           ERIC SWALWELL, California
VICTORIA SPARTZ, Indiana             TED LIEU, California
SCOTT FITZGERALD, Wisconsin          PRAMILA JAYAPAL, Washington
CLIFF BENTZ, Oregon                  J. LUIS CORREA, California
BEN CLINE, Virginia                  MARY GAY SCANLON, Pennsylvania
KELLY ARMSTRONG, North Dakota        JOE NEGUSE, Colorado
LANCE GOODEN, Texas                  LUCY McBATH, Georgia
JEFF VAN DREW, New Jersey            MADELEINE DEAN, Pennsylvania
TROY NEHLS, Texas                    VERONICA ESCOBAR, Texas
BARRY MOORE, Alabama                 DEBORAH ROSS, North Carolina
KEVIN KILEY, California              CORI BUSH, Missouri
HARRIET HAGEMAN, Wyoming             GLENN IVEY, Maryland
NATHANIEL MORAN, Texas               BECCA BALINT, Vermont
LAUREL LEE, Florida                  JESUS G. ``CHUY'' GARCIA, Illinois
WESLEY HUNT, Texas                   ERICA LEE CARTER, Texas
RUSSELL FRY, South Carolina
MICHAEL RULLI, Ohio
Vacancy

                                 ------                                

           SUBCOMMITTEE ON COURTS, INTELLECTUAL PROPERTY, AND
                              THE INTERNET

                    DARRELL ISSA, California, Chair

THOMAS MASSIE, Kentucky              HENRY C. ``HANK'' JOHNSON, Jr., 
SCOTT FITZGERALD, Wisconsin              Georgia, Ranking Member
CLIFF BENTZ, Oregon                  TED LIEU, California
BEN CLINE, Virginia                  JOE NEGUSE, Colorado
LANCE GOODEN, Texas                  DEBORAH ROSS, North Carolina
KEVIN KILEY, California              ZOE LOFGREN, California
NATHANIEL MORAN, Texas               MADELEINE DEAN, Pennsylvania
LAUREL LEE, Florida                  GLENN IVEY, Maryland
RUSSELL FRY, South Carolina          Vacancy

               CHRISTOPHER HIXON, Majority Staff Director
         AARON HILLER, Minority Staff Director & Chief of Staff
                            C O N T E N T S

                              ----------                              

                      Wednesday, December 18, 2024

                           OPENING STATEMENTS

                                                                   Page
The Honorable Darrell Issa, Chair of the Subcommittee on Courts, 
  Intellectual Property, and the Internet from the State of 
  California.....................................................     1
The Honorable Henry C. ``Hank'' Johnson, Ranking Member of the 
  Subcommittee on Courts, Intellectual Property, and the Internet 
  from the State of Georgia......................................     2

                               WITNESSES

Mark A. Cohen, Senior Fellow, Antonin Scalia School of Law, 
  George Mason University; Senior Technology Fellow, Asia Society 
  of Northern California
  Oral Testimony.................................................     4
  Prepared Testimony.............................................     7
Kent D. Baker, Head of IP Strategy, Litigation, Standards and 
  Licensing, u-blox America, Inc.
  Oral Testimony.................................................    22
  Prepared Testimony.............................................    24
Thomas F. Cotter, Taft, Stettinius & Hollister Professor of Law, 
  University of Minnesota
  Oral Testimony.................................................    44
  Prepared Testimony.............................................    46
Walter G. Copan, Vice President, Research and Technology 
  Transfer, Colorado School of Mines
  Oral Testimony.................................................    61
  Prepared Testimony.............................................    63

          LETTERS, STATEMENTS, ETC. SUBMITTED FOR THE HEARING

All materials submitted by the Subcommittee on Courts, 
  Intellectual Property, and the Internet, for the record........    83

Material submitted by the Honorable Darrell Issa, Chair of the 
  Subcommittee on Courts, Intellectual Property, and the Internet 
  from the State of California, for the record
    A letter to the Honorable Darrell Issa, Chair of the 
        Subcommittee on Courts, Intellectual Property, and the 
        Internet from the State of California, Dec. 18, 2024, 
        from the Coalition Against Socialized Medicine (CASM)
    A letter to the Honorable Darrell Issa, Chair of the 
        Subcommittee on Courts, Intellectual Property, and the 
        Internet from the State of California, and the Honorable 
        Henry C. ``Hank'' Johnson, Ranking Member of the 
        Subcommittee on Courts, Intellectual Property, and the 
        Internet from the State of Georgia, Dec. 17, 2024, from 
        the Council for Innovation Promotion (C4IP)
    A letter to the Honorable Jim Jordan, Chair of the Committee 
        on the Judiciary from the State of Ohio, the Honorable 
        Jerrold Nadler, Ranking Member of the Committee on the 
        Judiciary from the State of New York, the Honorable 
        Darrell Issa, Chair of the Subcommittee on Courts, 
        Intellectual Property, and the Internet from the State of 
        California, and the Honorable Henry C. ``Hank'' Johnson, 
        Ranking Member of the Subcommittee on Courts, 
        Intellectual Property, and the Internet from the State of 
        Georgia, Dec. 18, 2024, from ACT | The App Association

                 QUESTIONS AND RESPONSES FOR THE RECORD

Questions submitted by the Honorable Darrell Issa, Chair of the 
  Subcommittee on Courts, Intellectual Property, and the Internet 
  from the State of California, for the record
    Questions to Kent D. Baker, Head of IP Strategy, Litigation, 
        Standards and Licensing, u-blox America, Inc.
    Question to Mark A. Cohen, Senior Fellow, Antonin Scalia 
        School of Law, George Mason University; Senior Technology 
        Fellow, Asia Society of Northern California
    Question to Walter G. Copan, Vice President, Research and 
        Technology Transfer, Colorado School of Mines
    Question to Thomas F. Cotter, Taft, Stettinius & Hollister 
        Professor of Law, University of Minnesota
Questions submitted by the Honorable Scott Fitzgerald, a Member 
  of the Subcommittee on Courts, Intellectual Property, and the 
  Internet from the State of Wisconsin, for the record
    Question to Kent D. Baker, Head of IP Strategy, Litigation, 
        Standards and Licensing, u-blox America, Inc.
    Question to Mark A. Cohen, Senior Fellow, Antonin Scalia 
        School of Law, George Mason University; Senior Technology 
        Fellow, Asia Society of Northern California
    Question to Walter G. Copan, Vice President, Research and 
        Technology Transfer, Colorado School of Mines
    Question to Thomas F. Cotter, Taft, Stettinius & Hollister 
        Professor of Law, University of Minnesota
Questions submitted by the Honorable Ben Cline, a Member of the 
  Subcommittee on Courts, Intellectual Property, and the Internet 
  from the State of Virginia, for the record
    Question to Kent D. Baker, Head of IP Strategy, Litigation, 
        Standards and Licensing, u-blox America, Inc.
    Question to Mark A. Cohen, Senior Fellow, Antonin Scalia 
        School of Law, George Mason University; Senior Technology 
        Fellow, Asia Society of Northern California
    Question to Thomas F. Cotter, Taft, Stettinius & Hollister 
        Professor of Law, University of Minnesota
Responses to questions from Thomas F. Cotter, Taft, Stettinius & 
  Hollister Professor of Law, University of Minnesota, for the 
  record
Responses to questions from Mark A. Cohen, Senior Fellow, Antonin 
  Scalia School of Law, George Mason University; Senior 
  Technology Fellow, Asia Society of Northern California, for the 
  record


                   IP AND STRATEGIC COMPETITION WITH



                  CHINA: PART IV--PATENTS, STANDARDS,



                              AND LAWFARE

                              ----------                              


                      Wednesday, December 18, 2024

                        House of Representatives

           Subcommittee on Courts, Intellectual Property, and

                              the Internet

                       Committee on the Judiciary

                             Washington, DC

    The Subcommittee met, pursuant to notice, at 10:02 a.m., in 
Room 2141, Rayburn House Office Building, the Hon. Darrell Issa 
[Chair of the Subcommittee] presiding.
    Members present: Representatives Issa, Massie, Fitzgerald, 
Cline, Kiley, Johnson, Nadler, Ross, Lofgren, Dean, and Ivey.
    Mr. Issa. The Subcommittee will come to order. Without 
objection, the Chair is authorized to declare a recess at any 
time.
    Today, we welcome everyone here for this hearing on 
intellectual property and strategic competition with China. 
Before I recognize myself, I want to thank everyone for being 
here for what is clearly an investment hearing.
    I will now officially recognize myself probably for the 
same statement by my staff.
    Good morning. I welcome everyone to the hearing today. This 
hearing marks the fourth in a series of hearings focused on 
strategic competition with China. As this Committee has 
documented, the People's Republic of China has been leveraging 
the international IP system to serve their strategic interest.
    Our first hearing on the topic delivered China's--
recognition of China's intellectual property theft and the rise 
of national champions such as Huawei and ZTE. We looked at 
China's emergence as the largest filer of international patents 
and subsequent use of U.S. patents in litigations against 
American companies all with significant national security 
concerns.
    The second hearing examined how actions under the Biden 
Administration allowed greater foreign access to U.S. advanced 
technology by waiving IP protections under the TRIPS waiver 
provision. This failure threatened to harm U.S. innovation and 
jeopardize investments in life saving medical advancements.
    The third hearing analyzed the artificial intelligence arms 
race between the U.S. and China. We explored how Chinese AI 
development threatens a wide range of industries including our 
own cyber security.
    Today, we will address China's Standard 2035 strategy, a 
sophisticated and dangerous plan aimed at dominating critical 
global technologies by shaping international standards. This 
hearing will explore the PRC's manipulation of global standards 
setting organizations through overwhelming and coordinated 
participation in State-backed entities. I want to emphasize it 
is their leaning into organizations that often the U.S. does 
not fully staff to the level we could and, in fact, are often 
requested to, and that leaves a void, and China has happily not 
only filled the void but lobbied for more slots.
    China's unified effort to stack the deck at SSOs allows 
them to dominate the discussion and embed PRC technology into 
global standards such as 5G, AI, and the Internet of Things. In 
particular, we will investigate how the PRC exploits licensing 
and rate setting mechanisms for standard-essential patents in 
favor of Chinese companies. This behavior includes leveraging 
Chinese courts lacking independence or impartiality to set 
global licensing terms and undermine foreign competitors, 
particularly those in the United States. It includes suing 
competitors in the United States in the European Union by 
leveraging patents essential to important technology standards 
like 5G and others.
    Finally, this hearing will highlight the broader 
implications of the PRC's efforts including the erosion of U.S. 
technological leadership and the entrenchment of the PRC's 
dominant technologies into global infrastructure. Let us be 
clear. This Committee is not the Committee that will keep us 
from losing our lead. This is simply the canary in the coal 
mines. We cannot let the PRC dominate global standards and yet, 
as we speak, they have made significant advancements in the 
previous eight years, six years, four years, and two years, and 
as we speak.
    I want to thank our witnesses for their time today and as I 
said before the opening, this is the last hearing of this 
Congress, but a down payment on what we must do in the next 
Congress.
    It is now my pleasure to recognize the Ranking Member, Mr. 
Johnson, for his opening statement.
    Mr. Johnson. Thank you, Mr. Chair. Each of us has a cell 
phone, more than likely. Many of us look at that cell phone as 
just one single entity to itself. It is amazing that this same 
phone is held up by people across the world, looking at the 
coverage on Syria last week. You see folks holding up their 
phones recording the moment. These phones and other products we 
can't see inside, but there is not just one patent or one 
product in these phones or in many devices. It is made up of 
over a thousand patents, this phone. Some are owned by the cell 
phone manufacturer. Some are licensed by the owner. A few are 
known as standard-essential patents, or SEPs. These patents are 
designated SEPs by standards-setting, organizations meaning 
that they are necessary to make a cell phone work to global 
standards.
    The phones in our pockets are the very same as those in the 
pockets of people across the world because it is the same on 
the inside because they need to be interoperable so that people 
in Syria, China, and wherever else they are, can use them. I 
can call someone in Iran, and I guess maybe get them on the 
phone, same phone we are using.
    Mr. Issa. The Chinese will listen as you call.
    Mr. Johnson. That is true. Standard-essential patents 
guarantee worldwide interoperability of our technology. By 
requiring a universal set of patents for a device, global 
standards ensure that as technology advances, our machines are 
interoperable with the world around them. That is a good thing. 
These standards hinge on inventors being fairly compensated for 
their inventions so long as they agree to license their 
products on fair, reasonable, and nondiscriminatory terms known 
in the trade as FRAND.
    We are here today to examine the question of what happens 
when a country refuses to abide by the international process to 
which every other country adheres. Over the last decade, 
Chinese courts have advanced its government's technology-
dominance goals through legal decisions that put China out of 
step with the rest of the world. The Courts in China have set 
royalty rates artificially low for U.S. companies. They ruled 
in favor of antisuit injunctions that prevent litigants from 
bringing patent suits to other countries' courts, and otherwise 
prevented SEP owners from being paid fairly for their 
inventions.
    Transparency in litigation is another problem. Chinese 
court proceedings are infrequently published, making it 
difficult for litigants, international courts, and SEP owners 
to interpret rulings or to have any semblance of a rule of law. 
This absence of clarity has created a complicated system where 
the deck is stacked against American companies, one that is 
hard to navigate and where litigants struggle to receive a fair 
trial.
    I am looking forward to hearing from our witnesses about 
how we should approach this problem. We cannot expect, much 
less demand that the United States always come ahead. 
Similarly, it would be unwise to lower ourselves to the lowest 
common denominator, making our system similarly unfair to 
litigants who use systems other than the United States, or 
making the system unfair to patent holders would not even the 
score. Imitating China will not make the U.S. more American. It 
will take a worldwide effort to overcome China's overreach on 
SEPs. International institutions like the World Trade 
Organization should seriously consider whether Nations are 
meeting their obligations under the TRIPS agreement. We should 
be able to turn to international forums for fair adjudication 
of disputes, including the use of antisuit injunctions by 
Chinese courts.
    By working cooperatively through diplomacy and dialog, 
Nations disadvantaged by China's unfair decisions can demand a 
system that provides transparency and due process at a global 
level. America also has an obligation to lead the way. We 
should invest in making our patent courts faster, make sure we 
get more judges on the bench who are steeped in patent law, and 
attract litigation by having a better process in America for 
adjudicating disputes.
    Other countries will not follow the U.S. blindly. We need 
to prove we have a better process to incentivize litigation 
here at home.
    I thank my colleagues across the aisle. Chair Issa, I thank 
you for holding this hearing and working with me on a 
bipartisan basis over the last two years on all that we have 
worked on together. I thank Ranking Member Nadler for his 
support and for his friendship. I thank the witnesses for being 
here today. With that, I yield back the balance of my time, but 
not before wishing everyone happy holidays.
    Mr. Issa. Without objection, all other opening statements 
will be included in the record.
    It is now my pleasure to introduce our witnesses.
    First, we have Professor Thomas Cotter. Mr. Cotter is a 
Professor of Law at the University of Minnesota Law School. His 
research focuses on domestic and international intellectual 
property law, antitrust law, and economics. He is the author of 
seven books including several on intellectual property law.
    Next, we have Mr. Kent Baker. Mr. Baker is head of IP 
Strategy, Litigation, and Licensing of Intellectual Property 
and Standards for u-blox America which provides wireless 
semiconductor chips, modules, and other technological 
components. He is a patent attorney by trade and has more than 
30 years of experience in engineering and practice of law and 
academia on topics of intellectual property, standards policy, 
and regulatory policy. Welcome.
    Mr. Mark Cohen. Mr. Cohen is the Senior Fellow at George 
Mason University, Antonin Scalia School of Law, and a Senior 
Technology Fellow at the Asia Society of Northern California. 
He previously served as Senior Counsel to the Patent and 
Trademark Office.
    Dr. Walter Copan is the Vice President for Research and 
Technology Transfer at the Colorado School of Mines. He 
previously served as the Under Secretary of Commerce for 
Standards and Technology as the Director of the National 
Institute of Standards and Technology. Dr. Copan has served in 
a number of other positions in public and private life 
including as the Principal Licensing Executive for Technology 
Transfers at the Department of Energy's National Renewable 
Energy Laboratory.
    We welcome all our witnesses. We thank you for appearing 
here today. As is the rule of this Committee, would you please 
rise to take the oath? Raise your right hand.
    Do you solemnly swear or affirm under penalty of perjury 
that your testimony you are about to give will be true and 
correct to the best of knowledge and information and belief, so 
help you God?
    Thank you. Please sit down. Let the record reflect that all 
witnesses did answer in the affirmative.
    To all our witnesses here today, some of you have been here 
before. All of you have seen this on C-SPAN. We would like you 
to summarize what might be much more extensive comments to 
about five minutes. We won't cut you off mid-sentence, but we 
would appreciate getting to questions as quickly as possible. 
Your entire opening statements, plus additional information you 
may choose to give us afterwards will be included in the 
record, so you will be much more complete with the studious 
staff than you are to the public here today. With that, Mr. 
Cohen.

                   STATEMENT OF MARK A. COHEN

    Mr. Cohen. Thank you very much, Chair Issa, Ranking Member 
Johnson, Members of the Subcommittee, and staff for inviting me 
back to testify today. My comments focus on three SEP lawfare 
related issues, transparency, intervention in the markets of 
subsidies, and global rate setting. I echo Ranking Member 
Johnson's comments on the Chinese environment. My comments are 
directed to helping ensure that the U.S. system remains the 
leading system for adjudicating SEP disputes to support our 
innovative companies without compromising our values.
    Regarding transparency of the Chinese courts, I am 
generally referring to placing final court decisions online on 
the official Chinese judicial data base. During the last 
decade, this minimal type of judicial transparency has been 
decreasing significantly. In the past, only about 50 percent of 
patent cases were published. That number has since decreased, 
and I can't give you the exact amount. The number of published 
civil cases has declined by as much as two thirds. Chinese SEP 
cases today have been withdrawn from publication, anonymized, 
delayed, or not published at all. This curated, or perhaps 
censored approach, makes it impossible to answer basic 
questions about China's IP system such as China's compliance 
with international agreements including the Phase One 
agreement. The Phase One agreement, in fact, did nothing to 
advance transparency of judicial decisions.
    If there are to be any negotiations with China on IP, and I 
encourage them, a focus on transparency to better evaluate 
China's adherence to any commercial law commitment is 
essential.
    The next issue is intervention of the markets. China 
distorts its markets involving SEPs through subsidies for 
patent filings and grants and for subsidies for attending 
standards-setting bodies and even through awards. Patent 
subsidies have even been obtained by prisoners to mitigate 
their sentences.
    Some current subsidies, in Pudong, Shanghai, the subsidy is 
about $3,000 per patent grant. If a company wishes to establish 
a set patent pool, there is a one-time subsidy of about 
$160,000. In Shenzhen, there is a reward for high value SEP 
patents with corresponding PCT applications of about $160,000. 
Subsidies have often exceeded the cost of the patent 
application.
    Patent subsidies distort markets and burden overseas patent 
offices with low-quality patents. They may lead Chinese courts 
to unduly focus on quantitative, rather than qualitative basis 
for royalty calculations. They are leveraged to lower royalty 
rates. They burden companies with the additional expense of 
evaluating patent thickets of low-quality patents before they 
do business. Subsidies are also granted to firms for each 
proposal they submit to international standards bodies. These 
subsidies have led to a flood of low-quality proposals. We need 
to ask China to address the problem of IP and standardization 
subsidies and to ensure that it renews its efforts to focus on 
patent quality.
    Global royalty rates. China's long-standing efforts to set 
global royalties have taken various forms. The basic goal of 
Chinese courts is to set lower rates for FRAND royalties for 
implementation in China, thereby giving Chinese companies a 
competitive advantage over other markets. One of those efforts 
involves interference of the adjudication of SEP disputes by 
other countries. The Chinese courts deem the filing of a U.S. 
Section 337 action against Huawei as an abuse of dominance 
under its antitrust law about 10 years ago.
    Chinese courts have also issued antisuit injunctions to 
control actions by litigants in foreign courts. Such efforts 
are accompanied by extra territorial civil jurisdiction, 
exclusive use of China law for determining disputes, lower rate 
determinations for licensing to China, unique approaches to 
translating and applying FRAND, and efforts to regulate 
nonresident patent pools. These efforts that I have only named 
a few, low transparency, extra territorial jurisdiction of 
patent subsidies, threaten the global territorially based 
patent system and the global standardization system by 
extending China's reach, providing preferential treatment to 
China-based companies, and disregarding the integrity of other 
countries' legal systems, including our own.
    Thank you once again, and I look forward to your comments.
    [The prepared statement of Mr. Cohen follows:]
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    Mr. Issa. Thank you. Mr. Baker.

                   STATEMENT OF KENT D. BAKER

    Mr. Baker. Mr. Chair, and distinguished Members of the 
Committee, thank you for allowing me to speak today. I come 
from the trenches of IT warfare. u-blox is a small to medium 
size innovation company that provides wireless semiconductor 
chips, modules, and services that power the Internet of Things 
to reliably track, locate, and data connect everything. It is 
not voice-enabled. It is a data connection. To participate in 
standards organizations and associations such as Save Our 
Standards, which represents companies in agriculture, 
healthcare, energy, automotive, artificial intelligence, and 
several other industries. The u-blox modules allow devices to 
talk to each other with or without human intervention. We 
innovate and design fundamental wireless connectivity, 
components that can be used in any IoT machine or product that 
needs a wireless connection.
    You are going to find our modules in smart cities, water 
and gas meters, used with sensors for crop monitoring, 
robotics, after-market car alarms, industry floors, and much 
more. Even tracking adolescents or children for security 
purposes, that is how small these modules can be.
    I thought it would be useful to show you one. That is a 
module, a little light box you see here. This is a test board, 
certainly not that big in the product, but if I were to put 
power into this port with this switch, this will connect to any 
network. It will connect to your bay stations and cellular 
network. Don't be confused. This is the fundamental wireless 
connectivity that goes in every product, although granted, it 
will be miniaturized.
    There is a data port here, a serial type port. Anything you 
connect to it, car, laptop, whatever need you have, put your 
data in here, and this device is going to send it on to the 
network.
    As you see, the modules are very small, and they are easily 
overlooked. Issues regarding module security threats and the 
emerging Chinese dominance in the U.S. and IoT global markets I 
think has gone unnoticed.
    My intent is to bring to the Committee's attention four 
things.
    (1) There is a very real threat presented by Chinese IoT 
module manufacturers, U.S. communications systems, and Western 
manufacturers of IoT wireless modules. These may be companies 
you either never heard about or rarely read about. You may 
recall similar security issues arising recently with Huawei and 
ZTE cellular bay station products and handsets. Now, I am not 
sure why, but IoT modules were not part of that discussion. 
They certainly should have been. They present an equal or 
greater security risk than the mobile handsets did.
    Now, appreciate that these modules can talk to each other. 
They don't need a bay station. That is part of the reason that 
security risks can be even higher. When you have machines 
talking to machines without human intervention, that is a 
concern.
    (2) The eventual collapse of Western wireless module 
manufacturers such as u-blox and the loss of the $5 million 
global market due to Chinese companies having access to 
subsidies and centralized funding as Mark just commented on, 
and for us, it is specifically the CCP 13th and 14th Five Year 
Plans where these subsidies and additional funds are being 
called out specifically as part of an overall strategy.
    As discussed in my written testimony, Chinese company 
market share and revenue growth now dwarfs Western companies. 
At u-blox, we closely studied supply chain data, what does it 
take to actually build this module? We find Chinese companies 
selling the module at a profit for as low as $7.50 whereas a 
Western company can't build it for under $9 sans profit. A good 
question about how that happens without subsidies.
    Currently, Chinese companies are worried about the growing 
concerns in Western companies about the security and subsidies 
issues, so they are opening U.S. corporation storefronts to go 
ahead and sell their modules, and they appear to be Western 
sourced.
    (3) There is an understanding of how increasing 
participation at international standards organizations, a 
company can manipulate the system. If you send enough engineers 
into a work group, as we have seen happen with Chinese 
companies over the years, you will generate more patents, more 
invention disclosures, and it will put you in a dominant 
position to then manipulate the entire FRAND promise.
    (4) I suggest the U.S. take a leadership role that it has 
lost in patents and in the SEP-FRAND licensing debate. That 
will bring predictability and stability through IoT 
standardization for small and medium enterprises. SEP-FRAND is 
currently the Wild West. There are inspirational guidelines 
that we follow, but we know how well those guidelines work when 
there is money to be made. They simply don't. SEP-FRAND needs 
to be addressed and it needs to be defined.
    In closing, I think it is imperative that the U.S. protect 
national security and wireless IoT services and reject SEP 
licensing misconduct by any company. The U.S. must take down 
the artificial fence that has been erected between SEP holders 
and SEP users. Standards were created to proliferate technology 
and protect patent holders. It is time to stop the SEP-FRAND 
damage.
    [The prepared statement of Mr. Baker follows:]
    
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    Mr. Issa. Thank you. Professor Cotter.

                 STATEMENT OF THOMAS F. COTTER

    Mr. Cotter. Chair Issa, Ranking Member Johnson, and 
distinguished Members of the Subcommittee, I would like to 
provide a brief overview of litigation involving FRAND-
committed SEPs in what I view as the four leading 
jurisdictions, the United States, the United Kingdom, Germany, 
and of course, China.
    So, a little context. As you have already heard, some 
patents are essential to the practice of standards established 
by standard-setting organizations such as the European 
Telecommunications Standard Institute. SSOs typically have 
policies, encouraging or requiring members to license any such 
SEPs on fair, reasonable, and nondiscriminatory FRAND terms, 
but they do not define what FRAND means.
    So, one other thing to note is that patents are 
traditionally viewed as territorial rights, so a company may 
own a U.S. patent covering a particular feature, and also a 
portfolio of non-U.S. patents covering the same feature. So, as 
a result, when parties fail to reach agreement on the terms of 
the FRAND license, they could wind up litigating in any country 
in which products incorporating the SEPs at issue are sold.
    In the U.S., FRAND disputes make their ways to the courts 
by different paths.
    First, U.S. courts have concluded that FRAND commitments 
can create third party beneficiary rights, so an implementer 
may be able to assert that an offer to license on above FRAND 
terms is a breach of contract. Relatedly, sometimes either a 
SEP owner or an implementer may request a court to enter a 
declaratory judgment that the owner's offer is or is not FRAND. 
Another possibility is that a SEP owner will file a suit for 
patent infringement and the judge or jury will decide what a 
FRAND royalty is or the patents in suit. However, U.S. courts 
have not seen fit to award injunctive relief in these cases 
under the Supreme Court's eBay decision. One possible 
workaround for SEP owners may be to seek an inclusion order 
from the International Trade Commission, but in a 2013 case 
involving FRAND-committed SEPs, the U.S. Trade Representative 
vetoed on public interest grounds an order that would have 
precluded Apple from importing certain devices into the U.S.
    Finally, U.S. antitrust law so far has not played a major 
role in these cases largely because Section 2 of the Sherman 
Act is understood to forbid the willful acquisition on 
maintenance of monopoly power, but not its mere exercise or 
exploitation.
    Second, leading jurisdiction is the United Kingdom. In the 
U.K., these issues are typically litigated as patent 
infringement actions and over the past few years, the U.K. 
courts have developed a procedure whereby if a SEP owner 
succeeds in proving that the defendant is infringing one or 
more valid FRAND-committed SEPs, the court will offer the 
infringer a choice, either be enjoined from practicing the 
technology in the U.K., or agree to be bound by the terms of a 
global FRAND license to be determined by the court. We have 
seen that happen in a few cases.
    The third leading jurisdiction is Germany. In Germany and 
other civil law countries, injunctive relief is often viewed as 
being a matter of right, rather than equitable discretion. 
However, in the 2015 decision of Huawei v. ZTE, the Court of 
Justice for the European Union held that EU antitrust law 
constrains the owner of a FRAND-committed SEP from seeking 
injunctive relief unless certain conditions are met, one of 
them being that the implementer fails to express its 
willingness to license. German courts have interpreted this 
decision to mean that the implementers (willingness must be 
ongoing, and the end result is that in most cases, German 
courts find the implementer to have been unwilling and 
therefore have entered injunctive relief for the infringement 
of FRAND-committed SEPs. The German courts said that you had to 
actually establish the terms of a FRAND license.
    Finally, China, since 2013, Chinese courts have presided 
over cases involving FRAND-committed SEPs sometimes in the 
context of patent infringement actions or anti-trust actions or 
sometimes, as I understand it, as a sort of stand-alone cause 
of action. In recent years, Chinese courts also had expressed a 
willingness to determine the terms of global FRAND licenses 
where they believe there is a sufficiently close connection to 
China, and we had the first such determination of a global 
FRAND royalty just about a year ago in Nokia v. Apple.
    Last thing briefly, antisuit injunctions, these have 
actually been around for a long time in the U.K. and the U.S. 
The application of them to SEP cases actually began in the U.S. 
with the Microsoft v. Motorola case in 2013. More 
controversially in 2020, Chinese courts entered ASIs in five 
SEP cases forbidding parties litigating parallel actions 
sometimes anywhere else in the world. That seems to have gone 
away to some degree. Now, we don't think we have had any since 
2020 for a variety of reasons, but of course that could always 
be resurrected.
    [The prepared statement of Mr. Cotter follows:]
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    Mr. Issa. Thank you. Dr. Copan.

                  STATEMENT OF WALTER G. COPAN

    Mr. Copan. Chair Issa, Ranking Member Johnson, Members of 
the Committee, and distinguished participants, it's a privilege 
to testify on critical issues for U.S. innovation leadership, 
global economic competitiveness, and national security.
    It's my honor currently to lead research and technology 
transfer at Colorado School of Mines, a top tier U.S. research 
university rated in the top three engineering programs in 
America.
    I recently served our Nation as Director of the National 
Institute of Standards and Technology and prior with two of the 
U.S. Department of Energy National Labs.
    From my leadership experience in public and private sectors 
as a corporate executive, entrepreneur and investor, the 
requirements have clear, enforceable intellectual property 
rights and the right to exclude others is foundational to 
innovation success.
    Investors must confirm that an organization's IPRs will 
secure a protectable market position and provide pathways to 
achieve returns on investment as part of the justification to 
take on substantial investment risks.
    Strong IPRs enable innovators to advance technology 
leadership, incentivize investment, and create value, including 
from inventions essential to global standards.
    The United States is at a critical juncture regarding the 
future of American innovation leadership for the world. Our 
economic security and national security are closely intertwined 
with the reliability of the protections afforded by our IP and 
innovation system.
    The foundational strength of U.S. IPRs as established by 
the framers of the Constitution must continue with the 
enforceability of the rights of inventors in the U.S. and 
abroad together with the rule of law and respect for private 
contracts.
    The U.S. must once again lead the world by example through 
the development of IPR policies that support innovation at home 
and across jurisdictions.
    Reliable IP rights and contracts that are respected 
globally include the key role of standard-essential patents and 
the U.S. must demonstrate leadership in foreign markets 
including with the EU and China.
    This includes restoring the ability of rights holders to 
obtain injunctive relief and to avoid willful infringement and 
documented holdout by parties unwilling to enter license 
agreements with rights holders under FRAND terms.
    When such negotiations fail in a free market economy, 
Knowledgeable American courts can provide resolution with 
expertise and wisdom. All are essential for rebuilding and 
maintaining U.S. leadership and globally relevant standards 
today.
    The U.S. leads the world in key standards and, 
consequently, is a net exporter of innovation. Reliable IP 
rights, license to development, and manufacturing partners 
enable trusted global supply chains and value creation for 
consumers and for shareholders alike.
    The mobile telecommunications sector contributes an 
estimated total economic value of more than $4.8 trillion to 
the global innovation economy.
    Technology innovators, including holders of SEPs, gain 
returns on their investments in R&D and standards engagement 
through licenses and royalty payment in addition to products 
and services sales.
    The revenue flows from commerce in intellectual assets 
contribute positively to the U.S. trade balance with Chinese 
companies contributing over $70 billion in net IP payments to 
U.S. entities in 2020.
    However, there is widespread unlicensed technology use in 
China of innovations and IP assets owned by U.S. entities. 
Further, China's government has weaponized its legal system 
with a wide range of patent and competition law tools, price 
controls on international entities, forced technology 
transfers, and by providing selective legal protections and 
incentives seeking to advantage Chinese companies.
    There is a concerning movement away from market-based 
negotiations and valuation to government-controlled price 
regulation for standardized technologies.
    The EU has proposed a massive new regulatory regime toward 
government control of SEP prices. The Chinese Communist Party 
has followed suit, issuing guidelines that would apply its 
antitrust laws to SEP licenses to benefit Chinese entities.
    Supported by the Chinese government incentives and legal 
actions, Chinese technologies companies are gaining ground. As 
we look to rebuild America's advanced manufacturing base with a 
trained domestic workforce and trusted, resilient supply chains 
the U.S. must build on the strengths of our free-market economy 
and a reliable intellectual property and innovation system that 
continues to lead the world.
    I'm encouraged by some of the legislation proposed to 
strengthen the U.S. innovation system including the bipartisan 
Patent Eligibility and Restoration Act, the Promoting and 
Respecting Economically Vital American Innovation Leadership 
Act, and the Realizing Engineering Science and Technology 
Opportunities by Restoring Exclusive Patent Rights Act of 2024.
    Thank you to this Subcommittee for your important work 
toward securing the technology and innovation leadership for 
U.S. economic and national security.
    I look forward to answering any questions you may have.
    [The prepared statement of Mr. Copan follows:]
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    Mr. Issa. Thank you. I thank all our witnesses.
    We'll now go into five minutes per side of questioning, 
beginning with the gentleman from Kentucky, Mr. Massie.
    Mr. Massie. Thank you, Mr. Chair.
    I think it's important as we kick this off to talk about 
what SEPs are, or SEPs--standard-essential patents.
    Mr. Cohen, are these government creations or are these--
were these created by private industry, this nomenclature and 
this grouping of patents?
    Mr. Cohen. They're predominantly created by private 
standards development organizations which have private sector 
participants, although there are government standards, 
particularly in China, but also in the U.S.
    Mr. Massie. OK. Thank you very much.
    Dr. Copan, you joined several former administration 
officials--the former I say--to send a 2023 letter to the 
European Commission opposing the EU's draft of SEP regulation 
that would cap royalties for licenses of standard-essential 
patents and create separate centralized proceedings at the EU 
IP Office.
    Do you continue to have concerns about the efforts of 
foreign competitors to regulate our IP?
    Mr. Copan. I do, Congressman. Those concerns that I also 
included in my oral testimony are with respect to the overreach 
of governments to regulate free trade, fair commerce, and 
standard-essential patents and I stand by that joint letter.
    Mr. Massie. Aren't a lot of the patents created by U.S. 
entities and isn't it sort of insane to let countries not just 
China--we're here ostensibly about China but the EU is talking 
about doing the same thing.
    Because these patents are so important to things like 
national defense or our own competitiveness in the world 
economy isn't crazy to go along with this scheme in the 
European Union that would let them effectively nationalize our 
IP by setting the rate that could be charged globally for it?
    Mr. Copan. It is a huge concern. The United States' 
sovereignty over its intellectual property rights and the value 
that U.S. innovators create in global markets is something that 
needs to be part of a free-market economy and we know that 
sophisticated companies, developers, and implementers of 
technology have the guidance in fair, reasonable royalties that 
are nondiscriminatory and enabling the practice of commerce 
across borders without government interference.
    Mr. Massie. Well, I've heard some arguments that SEP--
standard-essential patents--are so important that you shouldn't 
be able to get injunctive relief--that the owners of the IP 
shouldn't be able to get injunctive relief.
    Do you agree with that argument?
    Mr. Copan. No, sir. The intellectual properties that are 
standard-essential patents are patents and deserve the same 
protections as the intellectual property rights of innovators 
in the United States and, indeed, protections in jurisdictions 
elsewhere, where intellectual property parallel protections 
exist.
    Mr. Massie. Let me ask, you mentioned some legislation that 
you were a fan of. What could we do in our own country with our 
own IP laws to improve American competitiveness and improve our 
national security?
    Mr. Copan. Definitely the improvement of clarity with 
regard to patentable subject matter as an important feature. 
Creating greater certainty in our courts on the basis which 
decisions are made in particular with respect to standard-
essential patents.
    I also believe it's very, very important for the United 
States to continue to lead by example, as I had indicated in my 
remarks, that the United States has a fair and reasoned process 
for adjudicating issues in our courts that enable rights 
holders around the world to trust the U.S. judicial system and 
that they know that the United States sets the highest standard 
globally for fairness in intellectual property matters.
    Mr. Massie. Mr. Cohen, I want to give you a chance to 
answer the same question. What do you think we could do here 
to--with our own IP laws to improve the signal that we send to 
other countries that we're the best country for developing IP 
in?
    Mr. Cohen. Well, I certainly agree with Dr. Copan's 
perspective on strengthening the domestic legal system in terms 
of patentable subject matter and availability of injunctive 
relief.
    There's another aspect in terms of the competition globally 
for a jurisdiction over FRAND disputes and parallel disputes 
that arise.
    So, we could find that even if we have the best system in 
the world, China can fast track its litigation so that a case 
will be resolved on appeal from beginning to appeal within nine 
months, according to the Chinese civil procedural law.
    At that nine-month stage we haven't even finished discovery 
in a U.S. District Court. So, having expedited procedures, 
perhaps, specialized tribunals, although I'm not a big fan of 
that, but at least slimming things down so that people can get 
a quick relief and having better assessment of the foreign 
competitive challenges.
    Now, I'd like to see our solicitor general from time to 
time appear in SEP cases to say whether a particular 
jurisdiction is fair or the potential disadvantages.
    I know one case in California where the judge was quite 
clear that by the time he renders a judgment in that case China 
will already have exhausted this appeal.
    We have to make our system more attractive in the global 
competition for litigation on SEP matters.
    Mr. Massie. Thank you both very much. I agree with you on 
injunctive relief here domestically. I yield back to the Chair.
    Mr. Issa. Briefly, Mr. Baker, did you have something else 
to add? You took copious notes.
    Mr. Baker. Yes. If you don't use injunctions correctly 
FRAND is absolutely meaningless. Injunctions were used because 
of a characterization called holdout where a company like u-
blox might not take a license.
    Unfortunately, if you look at especially foreign 
injunctions in Germany and over in China what you'll find is 
there's no FRAND analysis.
    It's the fact that, all right, here's something. We're 
going to assume it's FRAND. If you don't take that license we 
will issue an injunction. You can throw FRAND out the window 
with that.
    Also, with standard-essential patents the problem that you 
come up with is what it used to mean--and I was there in the 
work groups and I worked with DG GROW on why the entire 
competition SEP regulations coming out--it used to mean 
technical essentiality.
    Take it off the board. It doesn't work. Take the patent out 
of the module. It doesn't work. That's changed and it's been 
manipulated. That's the manipulation we're talking about.
    What we need is clarity in both what FRAND is and what a 
standard-essential patent definition means. Now, you're trying 
to control both.
    Mr. Issa. I have to keep it too brief. We'll continue.
    Mr. Johnson?
    Mr. Johnson. Thank you, Mr. Chair.
    Dr. Copan, could you enlighten us on how SEPs ensure 
worldwide interoperability?
    Mr. Copan. Thank you so much, Ranking Member Johnson.
    The technical committees working on international standards 
bring together science and engineering experts to consider the 
broad dimensions of a standard, for example, in advanced 
communications.
    The organizations participating in those standards 
processes provide data, provide insight to the rest of the 
Committee with respect to the technical operations and, 
ultimately, intellectual properties that underpin those 
features that are important to interoperability on a global 
basis as you had indicated in your comments as well enable the 
inventor--the rights holder--to participate in the standard-
setting process and then also through providing access to those 
intellectual properties on fair, reasonable, and 
nondiscriminatory terms, enables the actual practice then of an 
interoperable standard.
    Mr. Johnson. Thank you. How do international standards-
setting organizations go about designating SEPs and why is that 
process important?
    Mr. Copan. It is, indeed, a very important consideration. 
It is an analysis that's carried out by the committees on 
contributions to the standard itself and to the merits that are 
delivered by the intellectual property, by the invention, to 
the standard on a relative basis.
    So, there is a technical evaluation that's done of 
essentiality by the technical committee itself.
    Mr. Johnson. Thank you.
    Mr. Cohen, in your written testimony you told us that you 
believe that the WTO remains a viable option for airing our 
concerns and bringing multilateral attention to areas where 
China has departed from international practice.
    What SEP disputes do you expect to see at the WTO over the 
next five years?
    Mr. Cohen. That's a bit of a crystal ball exercise. 
Certainly, there's been a lot of frustration about the levels 
of the royalty rates that Chinese courts determine.
    I tend to think that Chinese practice of giving a 
preferential rate to a China-based company violates national 
treatment or most favored nation treatment obligations which 
are, of course, critical to the WTO generally.
    So, that would be one issue that I think is extremely 
important. There continue to be serious concerns about 
transparency, and I think those need to be clarified with China 
either diplomatically or at the WTO.
    The extra territorial nature of China's SEP litigation 
practice is being raised by the European Union at the WTO. The 
global rate setting is another level which deprives countries 
of their own sovereign courts to adjudicate their own sovereign 
patents, and I think that raises another level of concern about 
SEP litigation and kind of an over national focus by China to 
extend its reach globally.
    Mr. Johnson. Thank you.
    Professor Cotter, how does the absence of transparency in 
Chinese courts impact FRAND rate setting in other 
jurisdictions?
    Mr. Cotter. I think Mr. Cohen is correct that it is more 
difficult to find the Chinese cases than it is to find cases in 
other major jurisdictions such as certainly the U.S., but also 
the U.K. and to a great extent the European countries as well.
    So, it would be very helpful if those cases were more 
readily available and if they were available in some format 
where they could be translated either officially or at least at 
some high level so that others can actually understand what 
they say.
    I don't speak or read Chinese so I am always reliant on 
translations or reports of these cases, and so I think it would 
be advantageous if the cases were more readily available to the 
community generally.
    Mr. Johnson. Thank you.
    Mr. Chair, I'll yield back my three seconds.
    Mr. Issa. Thank you very much.
    With that, we'll go to Mr. Fitzgerald for five minutes.
    Mr. Fitzgerald. Thank you, Mr. Chair.
    Mr. Baker, Congress was just recently briefed about Salt 
iPhones and very concerning issues related to just how far that 
the CCP has kind of penetrated into the U.S. cellular networks.
    Do you have concerns regarding security and the 
vulnerabilities of Chinese technology? Obviously, there's an 
overall concern but specifically in our cellular, the modules 
that we use here in the States?
    Mr. Baker. Yes. There's an overall security concern not 
just in cellular but also there's a hybrid coming along which 
merges cellular with satellite and the two together there is a 
security concern about the information that you can actually 
take.
    I appreciate that these modules can talk to each other, 
which means you can bypass a base station. If you park your 
security software in the base station, you're probably not 
going to know that the machines are being corrupted.
    Mr. Fitzgerald. What could we do to protect the companies 
that we have all become very familiar with--the big cellular 
phone corporations?
    Mr. Baker. I think the corporations are capable of 
protecting themselves, especially those that came from--
Qualcomm was where I spent many, many years and we're perfectly 
capable of taking care of that given the opportunity to do so.
    Mr. Fitzgerald. Very good.
    Dr. Copan, this is more of a general question, and I know 
we have already had kind of a couple of others that dug down 
into this. The SEP portfolio is owned by Chinese-owned 
companies like Huawei.
    So, what are the risks associated with amassing such a 
portfolio of patents that also include the U.S. patents as 
well?
    Mr. Copan. Thank you, Congressman.
    The risk that we have seen in the application in particular 
in the courts in China is to take a numbers only approach, and 
regardless of the actual contribution of the intellectual 
property to the practice of the standard, by flooding the 
intellectual property system in particular in China and 
providing a massive stack of patent documents we have seen the 
Chinese courts actually favoring that type of approach rather 
than what we have seen in the U.K. courts or in the U.S. courts 
that take a much more detailed approach toward understanding 
the actual contribution of the intellectual property to the 
practice of the standards.
    Mr. Fitzgerald. Very good.
    Professor Cotter, can you please describe how the 
injunctions against the American companies sought by foreign 
companies in foreign courts hurt the U.S. economy? How can we 
draw that line?
    Mr. Cotter. Well, there are a variety of approaches, a 
variety of perspectives on whether injunctive relief should be 
granted generally for SEPs and the German courts and probably 
also the Unified Patent Court within the European Union take 
the view that injunctive relief is more a matter of right and 
so you usually get an injunction in those places.
    The UPC has just started up but in Germany, certainly, 
usually get an injunction. That puts tremendous pressure on the 
implementer to then reach a settlement, and maybe that is 
appropriate if the implementer is holding out is delaying the 
resolution of the case for strategic advantage.
    It also means that in many cases, I believe, the SEP owners 
are using the threat of injunctive relief potentially to 
extract an above FRAND license.
    So, part of this goes to why these FRAND commitments are 
required in the first place and that is to constrain SEP owners 
from exercising undue market power, raising prices, and 
ultimately harming consumers.
    So, the IP system has to be about balance, and I think that 
some degree of flexibility in awarding injunctive relief is 
appropriate. That's what we have in the U.S.
    It's also what we have in the U.K., and I would encourage 
other countries to follow that path rather than to make--rather 
than to making injunctive relief for SEP cases mandatory.
    Mr. Fitzgerald. Well, in bringing up the U.K. so is there 
an articulated or a specific type of framework in the FRAND 
determinations?
    What are your thoughts on that framework, and do you 
believe there's a concern that it's probably going to lead to 
greater instances of venue shopping in the U.K., right?
    Mr. Cotter. Well, I think the U.K. went to a place where I 
didn't expect. Let me rephrase that. In 2017, the U.K. became 
the first country, I believe, to set global FRAND royalties 
without consent of both parties. That was the Unwired Planet 
case.
    Many people and I was critical of that because it seemed 
like a bit of overreach. On the other hand, the last couple of 
times they've done that the rates that they have set have 
actually been relatively favorable to the implementers.
    So, if anything, they might be more attractive to 
implementers now than to SEP owners. I will say that I think 
the U.K. judges do a very decent job. They're very thorough, 
very detailed, very well respected.
    So, in some ways the U.K. model has proven to be quite a 
good one. Doctrinally the idea is you'll either be enjoined or 
you let us set a global FRAND rate.
    One predictable consequence of that was that other 
countries such as China would then follow suit and do the same 
thing.
    Mr. Fitzgerald. Thank you. I yield back, Mr. Chair.
    Mr. Issa. I thank the gentleman.
    We now go to the Ranking Member of the Full Committee, the 
gentleman from New York Mr. Nadler.
    Mr. Nadler. Thank you, Mr. Chair.
    Dr. Copan, American companies' ability to invest in R&D 
ensures that our patents 10 years from now are competitive with 
Chinese companies.
    How can investments in American R&D affect our national 
security over time?
    Mr. Copan. Thank you so much for that question, 
Congressman.
    The ability of the U.S. to invest from the private sector 
and to see value creation in the global marketplace is an 
essential part of the workings of a global economy.
    These connections, however, between national security and 
economic security are very, very clear and direct at this time, 
and so the health of the U.S. corporations that have a global 
play and also the ability to license under FRAND terms in ways 
that truly provide returns on investment for U.S. industry to 
continue to drive forward research and innovation and lead the 
world is essential also for national security.
    Mr. Nadler. Thank you.
    Mr. Cohen, we have seen the Chinese government use antisuit 
injunctions in the past in a manner that I have characterized 
as bullying, but then seemingly move on after being challenged 
on the global stage.
    Moving on does not mean they have stopped abusing the legal 
system, right?
    Mr. Cohen. Moving on for China in this case means, I 
believe, that the EU WTO case forced China to at least put a 
pause on antisuit injunctions, not to stop them entirely, and 
what we have seen is the evolution of judicial practice toward 
global rate setting and greater extraterritorial reach of the 
courts.
    So, we're hardly beyond the problem of China setting rates 
for SEPs outside of its territorial jurisdiction.
    Mr. Nadler. Let me ask you a question that you may have 
partially answered just now. Can you describe some of the new 
tactics the Chinese government has adopted to reach the same 
ends? Given that the Chinese government is clearly skilled at 
taking advantage of different legal regimes as needs arise, 
what would be an appropriate response from the U.S. Government 
in conjunction with our allies?
    Mr. Cohen. Well, let me begin by--the second part of that 
question. I think the appropriate response if possible is to be 
as multilateral as possible. I think that could mean using the 
United Nations or negotiating through vehicles like the IP5 or 
the U.S. PTO with the other four largest patent offices or 
engaging our antitrust authorities also to engage with the 
Chinese counterparts.
    The issue is the continuing--in Chinese there's a saying, 
``you have a policy; I have a counter-policy.'' What we've seen 
in China is the continual evolution of counter-policies that 
rarely get to the bottom line. That's part of our problem with 
the WTO itself because you can't really amend your complaints 
with the WTO. You have to file another complaint. So, that's a 
limitation. We really need the focus of all our trading 
partners on this industrialized--this industrial policy 
approach to FRAND and separate--
    Mr. Nadler. Should we try to get the WTO to allow the 
modification of complaints that you just said?
    Mr. Cohen. Yes, I think that would help, frankly, because 
otherwise we're filing disputes on yesterday's issues.
    Mr. Nadler. Thank you. Mr. Cohen, I understand that the 
Chinese Government's approach to dominating standards has 
included subsidies for patent applications for technology 
related to standards. Can you elaborate on this practice and 
describe its implications for what kind and how many patents 
Chinese companies might get?
    Mr. Cohen. That's a great question. The numbers are in the 
thousands, if not tens of thousands. It's not limited to SEPs, 
but at least in the SEP area there's a bigger focus of 
litigation. It's resulted in overall a lower quality for 
Chinese patents. It imposes a burden on patent offices because, 
as any skilled bureaucrat knows, they have to use end-of-year 
money. If they have subsidies at the end of the year, then 
everybody wants to file them to get those subsidies.
    We've seen lower quality Chinese patents the last quarter, 
in the fall. In fact, I joke sometimes that if China wants to 
improve its innovative ecosystem, they just have to ban autumn. 
So, what we've seen is China using that quantitative advantage 
to achieve an advantage in the courts, because courts and 
sometimes antitrust agencies frequently rely on patent counts, 
and they don't want to go through the more laborious task of 
qualitative analysis.
    Mr. Nadler. Thank you. Finally, how does this practice 
affect global rate setting and what is the best way to ensure 
that rates reflect patent quality rather than quantity as you 
just said?
    Mr. Cohen. Yes, I've already partially addressed that. It 
clearly addresses rate setting, particularly by agencies that 
rely on counts. I think the more we bring new information to 
the table--PTO did a great report I think about four years ago 
on the quality of Founding SEP patents. They also did it on 
trademarks. They pointed out the pernicious effect of patents, 
of subsidies on that. I think we need to do more of that, 
bringing it out into the open air because it's not discussed 
enough.
    Mr. Nadler. Thank you, and I yield back.
    Mr. Issa. I thank the gentleman.
    We now go to the gentleman from California, Mr. Kiley, for 
five minutes.
    Mr. Kiley. Good morning. Mr. Baker, if I could start with 
you, I think you made a comment about how we need more of a 
leadership role for the United States when it comes to 
standard-setting organizations. I wanted to ask you just what 
are the ways that we could do that? There are examples of 
standard-setting organizations that have managed to keep the 
Chinese influence at bay through appropriate governance 
measures, so maybe that is one route. Maybe in other cases 
where China is gaining influence legitimately, how could we 
step up our involvement in these organizations, provide 
incentives for participation to match their influence?
    Mr. Baker. That's an excellent question because one of the 
things that happens with U.S. corporations that are not 
subsidized, when your budget goes down and your returns go 
down, you reduce your staffing at standards organizations. 
Doesn't occur with Chinese companies. When they're subsidized, 
they increase the number of individuals.
    As far as participation, remember it's a technical 
standard. The idea of more engineers is a good thing. I will 
disagree with one thing. The standard essentiality of something 
that's put into a standard is not addressed by a work group. 
I've been in the work groups and that is specifically excluded. 
The technical elegance is what's included in the standard and 
you sort out the SEP-ness. The pProblem is nobody's sorting out 
that SEP-ness. It's a big question mark.
    So, as far as participation, a great start would be having 
an initial threshold as far as the number of participants that 
could represent a company at a standard, changing voting rights 
so that the voting rights are reflected based on an individual 
company gets one vote and other such procedural methods. Some 
standards have implemented them; many others have not.
    Mr. Kiley. So, how could we sort of have more of a voice in 
setting those rules of governance?
    Mr. Baker. That's a difficult question because the whole 
idea of the standardization setup is to have it privatized 
under the Western philosophy. In China it's slightly different.
    Mark, you know more about that than I do.
    As far as the government being able to regulate it, there 
are certain programs where there is a role for government to 
play in trying to be figuring out the staffing levels for 
particular standards.
    Mr. Kiley. Let me revisit this question of sorting out the 
SEP-ness, as you put it, which refers to whether the patent is 
truly standard-essential. You made a comment earlier about how 
true essentiality was a matter of whether the device needs to 
have that technology to work. That seems maybe not quite 
technically the case. Isn't it a matter of whether you need to 
practice the patent to achieve compliance with the standard, in 
which case having a standards-essential patent is kind of like 
a tautology because once it is in the standard you have to use 
that technology to achieve interoperability? So, which is it?
    Mr. Baker. Congressman, it's actually--you're describing it 
correctly, but the technical essentiality is part of the 
interoperability of the standard. If you take out that 
technical essentiality, it's not going to be interoperable.
    Mr. Kiley. Right. So, there is the question of whether 
technology is necessary for a device to work and then there is 
the question of whether it is essential to achieve 
interoperability. The latter question is just a matter of the 
choice that was made in the standard-setting process, right? 
Different choices could have been made to use different 
technologies to achieve the same level of interoperability.
    Is it your argument that this essentially renders it not a 
SEP patent or does that go to the setting of FRAND rates 
because there exist viable alternatives, not to practicing that 
particular standard, but rather to achieving some level of 
technical interoperability?
    Mr. Baker. You're actually hitting on a very good point 
because there are different parts of a standard. There can be 
the main part of the standard and there can also be appendices 
to the standard. So, if you're talking about what is the most 
technically elegant way to achieve something given all the 
engineering parameters around what that standard seeks to 
achieve, that would be what's technically essential. That 
doesn't mean a different way of doing it in a different part of 
the standard would not yield standard-essential patents if you 
implement that part of that standard.
    Mr. Kiley. All right. Interesting. Yes, it seems like an 
area worth exploring. I guess part of the issue is that there 
is just such a mess in terms of what the standard is--probably 
a bad word to use standard again, but what the framework is for 
setting FRAND rates that has created all this confusion and 
uncertainty.
    But, Dr. Copan, I wanted to also give you an opportunity 
here because I was glad you mentioned the PERA, which I have 
introduced, a piece of bipartisan legislation bicameral, which 
would go a long way toward clarifying subject matter 
eligibility, creating more certainty for those who are looking 
to innovate.
    Could you talk a little bit more about how that is 
particularly relevant to the general theme of today's hearing, 
which is the ways in which China has come to use dominance of 
intellectual property as a major tool against the United 
States?
    Mr. Copan. Thank you so much, Congressman Kiley, and 
grateful for your leadership in PERA.
    The opportunity to provide greater clarity on patentable 
subject matter is absolutely important in the United States 
with respect to the enforceability of IP rights, as well as to 
understand how they read on the practice of a standard. That 
clarity benefits not only the United States practitioners, but 
companies from other Nations as well seeking to access the 
United States market.
    Mr. Kiley. Thank you. I yield back.
    Mr. Issa. Thank you. I now ask unanimous consent that three 
letters to the Committee in support of today's hearing be 
placed in the record. The first is from the Coalition Against 
Socialized Medicine. The second is from the organization, the 
Council on Innovation, C4IP. The third one is from the App 
Association.
    Without objection, all three will be placed in the record.
    We now go to the gentlelady from North Carolina, Ms. Ross.
    Ms. Ross. Thank you, Mr. Chair.
    Thank you to all the witnesses for joining us today on this 
very important topic.
    I represent North Carolina's Research Triangle, so I know 
firsthand that our Nation's leadership in technology and 
innovation depends on strong intellectual property protections. 
Among the most critical tools in this regard are standard-
essential patents, SEPs. The backbone of technologies like 5G, 
Wi-Fi, and advanced video compression allow companies to build 
interoperable products globally.
    The American innovators, as we have all discussed, then 
license these patented technologies to Chinese and other 
foreign implementers. The royalties from these licensing 
agreements account for a significant share of the U.S. 
innovators' R&D and positive trade balance.
    As we have heard, China is actively undermining U.S. 
leadership by devaluing these patents directly harming American 
innovators and weakening their ability to compete globally. 
There are also national security threats in this situation. 
These tactics threaten innovation and risk ceding U.S. 
leadership for emerging technologies to China at a time when 
the State Department report shows that the U.S. already lags 
behind China in 37 of 44 key tech sectors from AI to 
biotechnology.
    We need to defend the ability of American innovators to 
license their patents under fair, reasonable, and 
nondiscriminatory terms, FRAND, as we have been discussing, and 
push back against foreign efforts to impose artificial royalty 
limits.
    Further, we must condemn China's abusive practices, 
including judicial overreach, that harms our IP holders and the 
integrity of international agreements like TRIPS. By doing so 
we can preserve the incentives that fuel technological 
breakthroughs and maintain our edge in global standard setting. 
As we face competition from China defending intellectual 
property rights is both an economic and a national security 
imperative.
    Dr. Copan, in a 2022 comment you co-signed for the Renewing 
American Innovation Project on multiagency SEP policy you noted 
how devaluing U.S. patents is akin to subsidizing tech transfer 
to China. How should Congress, the Administration, and the 
private sector ensure that companies play a leadership role in 
R&D and standard setting for the next generation's critical 
technologies? For example, does the U.S. need to increase its 
leadership in standard-setting bodies and voluntary standard 
development organizations?
    Mr. Copan. Thank you so much for that important question, 
Congresswoman Ross. It is absolutely essential for the private 
sector-led process in standardization to be well understood as 
a national security imperative of the Nation. The conversations 
here today have discussed the importance of encouraging U.S. 
industry to maintain their presence and to contribute actively, 
also in partnership with the U.S. Government, with 
organizations such as the National Institute of Standards and 
Technology at the table with a role as partner and supporter to 
the private sector.
    The opportunity is absolutely essential for the Nation to 
continue to have enforceability of intellectual property rights 
on a global basis to work with trade organizations and also 
with WTO to ensure that the United States' position is 
supported and that the erosion that we have seen of 
intellectual property value by the actions taken by the Chinese 
courts is condemned by the United States and like-minded 
Nations.
    Ms. Ross. Thank you.
    Then, Professor Cotter, I know we only have a few seconds 
left so I will make my question short. You talked about what 
goes on in courts around the world, but when it comes to 
setting countries' royalty rates would you agree that it is 
more efficient and fairer to let IP innovators and implementers 
negotiate a rate at arm's length as opposed to having outside 
intervention?
    Mr. Cotter. I would say that ideally negotiations are best, 
but it is often the case, particularly in this particular 
sector, that the negotiations cannot take place before the 
implementers are locked into particular technological choices. 
So, when that happens, I think there is a necessary fallback 
for the courts to make decisions in appropriate cases when 
negotiations fail.
    Ms. Ross. Yes. Correct. Thank you so much.
    Mr. Issa. I thank the gentlelady.
    We now go to the gentleman from Virginia, Mr. Cline, for 
five minutes.
    Mr. Cline. Thank you, Mr. Chair.
    Mr. Baker, I am looking at your testimony about what should 
be done and how to regain leadership in the SEP-FRAND licensing 
process to make sure all SEP holders receive fair compensation 
for the use of its actual SEPs by all SEP implementers. It is 
your testimony that both China and the EU have proposed 
oversight to remove the cloak and veil from SEP-FRAND 
licensing, provide guidance and level the licensing playing 
field between SEP holders and SEP implementers.
    How does that give the Chinese a strategic advantage to 
remove that cloak and veil?
    Mr. Baker. I don't necessarily agree with the process by 
either of those entities are approaching the subject matter, 
but at least they're making an attempt to address how you 
identify a standard-essential patent and also FRAND. Remember 
that this FRAND commitment--and Mr. Copan I think said about 
honoring contractual rights--when a patent holder, a SEP patent 
holder makes an agreement into a--participate in a standard, 
they get a quasi-
monopoly which proliferates not only the standard, but also the 
use of their patent, which means they're addressing a much 
broader market.
    The ability to actually define what is a SEP and also give 
some parameters, some guard rails around what FRAND means, I 
think those are advantages.
    Mr. Cline. Your company manufactures modules for standard-
compliant communication devices. Does your company pay 
licensing fees for SEPs as a result?
    Mr. Baker. Yes, we're a proactive licenser and one of the 
biggest frustrations we have is trying to license from China 
companies such as Huawei and ZTE.
    Mr. Cline. Do your Chinese-based competitors pay these 
licensing fees?
    Mr. Baker. Ha-ha. Nobody really knows, but I would say no 
based on the fact that they're selling a module, as I stated, 
that we can't even make it at, and they're making huge profits.
    Mr. Cline. Obviously, that has a significant impact on your 
business when they are making these profits?
    Mr. Baker. I would say that it's probably driving Western 
module manufacturers out of business. If you want to have only 
Chinese providers of modules, that's the path you're on.
    Mr. Cline. When we consider what has happened recently with 
Chinese essentially intervention in the cell phone technologies 
and, for lack of a better term, hacking into the cell systems 
of American companies, the pushing out of every other kind of 
manufacturer--this is getting worse, not better, correct?
    Mr. Baker. Correct. I should add exponentially worse. It's 
an ever-evolving rate.
    Mr. Cline. So, your company is an SME that implements a 
number of technical standards and you have firsthand experience 
in licensing of SEPs. You walked us through the process of 
licensing SEPs for an SME. How do you assess the value of a 
particular SEP during licensing negotiations?
    Mr. Baker. Now, appreciate for our method may not be one 
that's followed by every company, and the reason for that being 
a small/medium-sized company. We don't have a deep pocket to do 
a tremendous amount of analysis, but what we do is a 
statistically significant analysis. So, when presented with a 
portfolio of 1,000 patents, we'll take 100 of them. We will 
independently look at those to determine, both internally and 
through external experts, whether or not they truly read on the 
standard.
    The declaration that's filed by a patent holder, a SEP 
holder into a standards association has zero relevance to its 
actual SEP-ness. So, we actually undertake that burden to do 
that. That's unique in the industry. We do it as an--it's an 
overhead cost. That's the only way we can have an idea, first, 
we are actually using the patent in our product; and second, 
what would be a reasonable valuation because are the patents 
you hold incremental improvements or are they something truly 
monumental and early technology like millimeter wavelength 
coming out of 5G? That's brand-new stuff. That's going to be 
pricey.
    Mr. Cline. Is there a way that you envision that we can 
improve the efficiency of the system or--
    Mr. Baker. If there was an ability to actually have a 
determination of whether or not--close the loophole. You have a 
declaration put into a standards group where I believe it's 
going to be standards essential. You've got a patent over here 
in another dynamic system going through the patent evaluation 
system at the U.S. PTO. The two never come together to 
determine SEP-ness. So, you don't even know if that originally 
filed belief declaration has anything to do with the actual 
technology in the patent issued.
    One thing that would be good would be to harmonize the 
issued patent with that original declaration and see if that 
technology actually made it into the standard.
    Mr. Cline. Thank you. Yield back.
    Mr. Issa. I thank the gentleman.
    We now go to the gentlelady from Pennsylvania, Ms. Dean.
    Ms. Dean. Thank you, Chair Issa, Ranking Member Johnson, 
and, of course, to all our witnesses today, thank you for your 
expertise and for sharing this information.
    I would like to go back. In a former life I was a professor 
of writing at La Salle University, and I really emphasized to 
my students the value of plain--English. I can't even say it. 
Plain English. For the nontechnical IP and technology folks out 
there, can we go back and tell me, tell us what is SEP? I am 
laughing because you talked about SEP-ness. I never even heard 
such a word. Excuse me for my ignorance. But could we go back? 
For everyday Americans, what is a SEP? What are standard-
essential patents and what are the criteria to become one? 
Maybe Mr. Copan? Dr. Copan?
    Mr. Copan. Thank you so much for that question. I 
appreciate the focus on clarity in writing, communication, and 
thank you for raising that.
    Patents provide innovators with the ability to practice 
their invention in the marketplace and the ability to exclude 
others. In the case of SEPs the inventor agrees to make that 
invention available to everyone who wants to practice a 
standard that would also be available then on fair reasonable 
and nondiscriminatory terms. So, it really is a commitment to 
make an invention broadly available to those interested in 
practicing.
    Ms. Dean. Thank you. I appreciate that.
    Mr. Baker. Ms. Dean, if--
    Ms. Dean. Oh, I am sorry. Yes, thank you, Mr. Baker.
    Mr. Baker. I'm going to make this very simple. If you have 
a car and you take the tires off it, it doesn't work. Those 
tires are standards-essential to the operation of the car. It's 
that simple. It's not a long definition. I was there when we 
wrote the policy guidelines. The language was simple, and it's 
currently being totally manipulated on what the original intent 
was by other people taking that simple language and trying to 
tell us what it means. I wrote the darn guidelines. I can tell 
you what it means.
    Ms. Dean. That is very helpful. Anecdotes like that are 
very helpful to me.
    Mr. Cohen, we have heard arguments today, and I am 
following up really on what Mr. Massie was talking about, that 
SEPs are so important to certain technologies that SEP holders 
should not be able to obtain injunctions or exclusion orders, 
but doesn't that run the risk of devaluing U.S. IP rights? Why 
shouldn't SEP holders have the same rights as other patent 
holders to enforce their IP in court?
    Mr. Cohen. Yes, I think Professor Cotter's given a brief 
explanation of why there's a different kind of balance with 
regard to SEPs; that is, that a SEP could be abused to exhort 
an exorbitant monopoly rate when it should be made available on 
fair, reasonable, and nondiscriminatory terms.
    In theory, if you violate that obligation and negotiation, 
maybe you should be deprived of the right to an injunction, but 
you should still be entitled to a robust royalty, whatever the 
appropriate royalty is. That's kind of the tradeoff for 
inclusion of the SEP in what is more or less a public good, 
which is standard.
    Now, having said that calculation, which was first 
expressed in a case in Europe called Huawei v. ZTE, can easily 
be abused. What constitutes good-faith negotiations? How much 
do I have to disclose? What if the implementer delays and 
delays for years and years? In a world such as China where they 
insist in equality in rates, shouldn't I disadvantage the party 
who has delayed and delayed in coming to the table and 
negotiating? It shouldn't only be one-sided on the side of the 
inventor or the patent owner. You have to also look at the 
behavior of the implementer.
    Mr. Dean. Do you have any comments on a bill that I am a 
part of with Representative Moran, the RESTORE Act, which I 
think was talked about before I came into the hearing. I 
apologize for missing that. It would provide patent owners who 
have proved infringement in court the rebuttable presumption 
that they are entitled to an injunction to protect the patent. 
I believe in strong patent rights and strong IP rights. They 
are essential. Do you have an opinion on RESTORE?
    Mr. Cohen. Well, I can say that it severely disadvantages 
U.S. courts in the competitive battle to assert jurisdiction 
over FRAND disputes to rarely have an injunction available when 
there is infringement, including when there is delay. It 
particularly disadvantages those companies that may not be 
implementing that may simply be engaged in licensing the 
patents.
    We should keep in mind that the U.S. is the largest 
licensor of technology in the world by a long shot, and a large 
part of those licensing agreements, particularly in markets 
like China, are unrelated parties, so it's not General Electric 
to its subsidiary. It's a Qualcomm to an OPO, or whatever the 
case may be. This is really important for the innovative 
capacity of U.S. companies to derive the appropriate amount of 
revenue.
    I believe that I support this proposal to go back or have a 
presumption of availability of injunctive relief.
    Ms. Dean. I appreciate that.
    Mr. Chair, thank you. I yield back.
    Mr. Issa. I thank the gentlelady.
    We now go to the gentleman from Maryland. As long as he 
promises not to mention the Army-Navy game, I will grant him 
five minutes.
    Mr. Ivey. Thank you, Mr. Chair. I have ribbed my Governor 
enough about that game, so I will leave it at that.
    Just to followup on what Ms. Dean just asked--I think it is 
Dr. Copan--you mentioned the RESTORE Act in your written 
testimony, I believe in your oral testimony as well. I was 
curious about your answer to Ms. Dean's question about the view 
about that bill.
    Mr. Copan. Yes, thank you so much. Indeed, I did mention 
that in my testimony, the important step forward that 
represents for U.S. innovators.
    I do believe that it is important to provide that kind of 
position of strength for the United States innovators to know 
that they have the ability to take action in support of their 
invention and to deal with bad behavior in the marketplace 
those who are holding out, and indeed to have clarity also in 
the courts of the ability to move forward with injunctive 
action when other remedies fail.
    Mr. Ivey. Thank you. Mr. Baker, I want to go back to your 
testimony. You said--let me just--I will phrase it as a 
question. How do we keep Western module makings in business, 
because I think your testimony was the way things are moving; 
they will be forced out of business in relatively short order?
    Mr. Baker. Leveling the playing field. We're a component 
manufacturer. We do not operate at the end-product level. 
Leveling the playing field with predictability within the 
marketplace so that we know that when we are making a component 
we not only have access, direct access to patent rights which 
allows us to innovate--because when you have this module that's 
standard-essential and you're using it, you then have to take 
this module and you have to integrate it into whatever the 
device is, whether it's a car alarm, whether it's a tracking 
device. So, we are innovators also. We need direct patent 
rights, which means a direct patent.
    If you go ahead and you do just end-product licensing, what 
you make as a commoditized producer and manufacturer of these 
products, that only serves the Chinese purposes even more so 
because of the way that they actually do business. Leveling the 
playing field and requiring everyone who is participating and 
using those patents to have predictability in how much we will 
need to pay for the patents in an aggregate form and also what 
is the true value of the collective standard-essential patents 
used by that product, that would go a long way to keeping us in 
business.
    Mr. Ivey. Let me generalize on your answer there, because I 
think there have been a number of comments in the testimony 
about how to deal with the activities of the Chinese and how to 
sort of address some of the misconduct. We are going to make 
efforts, we are going to pressure them, we are going to join 
different organizations and exert additional influence. Not to 
be cynical, but I don't know that they are always responsive to 
those sorts of things.
    What actual sorts of legal and economic leverage do we have 
that we can assert to force more egalitarian behavior or more--
a level playing field of behavior, so to speak, with respect to 
the way China's handling these issues?
    I will start with Mr. Cohen, I guess.
    Mr. Cohen. Yes, it's a great question. It's one that I 
think of constantly. Obviously, one response is tariffs. So, 
that's something that I think President Trump is probably going 
to look at.
    Mr. Ivey. That is timely, yes.
    Mr. Cohen. So, that--
    Mr. Ivey. Elaborate on that a little bit. What is your take 
there?
    Mr. Cohen. Well, the problem I have with tariffs is that if 
you start imposing tariffs for an IP-related issue, it's going 
to invite retaliation by China perhaps on our own IP rights in 
China. So, I'm concerned about China's capacity to cross-
retaliate.
    We have an IP system that to this day basically treats 
every part appearing in a U.S. court, foreign, national, or 
local equally. We begin to erode that system. We have to really 
think of the global consequences of eroding that system. That 
concerns me because we're seeing the erosion of MFN concepts in 
tariffs. Is IP next? What are the consequences for that? That's 
something to think about.
    Mr. Ivey. Let me go to Mr. Baker.
    Mr. Baker. Look, I have to agree with the tariffs also. 
Although we are not strong supports of subsidies, if we're 
going to level that playing field, you have to look at all 
options.
    Mr. Ivey. Mr. Cotter?
    Mr. Cotter. I think the options--it's very difficult to 
figure out what the options are for compelling China or any 
other nation to do what we want them to do with regard to 
intellectual property. Most of it I think is going to have to 
be carried on through diplomacy, where possible through the 
WTO, but that is something that is something that takes a lot 
of time and has its defects.
    Mr. Ivey. Doctor? Still looking for the cudgel here.
    Mr. Copan. Yes, I think that this is a challenge that also 
can involve stopping importation of goods into other Nations 
that are very clearly infringing. As China seeks to access 
global markets, working with other Nations to ensure that 
they're not accessing them with infringing products is an 
important step to consider.
    Mr. Ivey. Thank you for your comments. I know that you had 
additional things that you wanted to say. My time is expired. I 
yield back. Thank you for your testimony.
    Mr. Issa. It was a good use of your time.
    Last and probably least, I am going to wrap this up with a 
group of questions.
    First, I would like to let you know that we had four pages 
of questions with followups and we didn't get to them all. So, 
we will be sending those to each of you and asking you to 
respond for the record, but there are a number of things that I 
think in summary that I would like to touch on.
    Second, although this hearing was very much put out as 
relative to China, I think it is fair--and an acknowledgment 
from all of you that there is no question at all that although 
China is the most unfair player, there are deep concerns on 
this panel about Britain, Germany, and the EU, in general, and 
their desire to lower their cost of SEP licensing. Is that fair 
to say?
    Mr. Cotter. If I may, I'm not sure that I would 
characterize it that way exactly. I don't think honestly that 
the courts in these countries necessarily have an agenda. They 
have very different perspectives. So, the U.K. courts, probably 
the most similar to our own, take a fairly balanced approach to 
these issues. The German courts, as I've mentioned, see 
injunctive relief as a matter of right, and so that tends 
actually to give the SEP owners the advantage in those cases.
    That may change. As I mention in my written testimony the 
European Commission may have other views on that but remains to 
be seen.
    Mr. Issa. Mr. Baker, that last point, if the whole world 
decided that SEP is great but injunctive relief is essentially 
the default, how would that affect your ability to go to 
market?
    Mr. Baker. It would effectively shut us down. The 
injunctions without first an analysis of whether or not an 
offer is FRAND, you can't determine if there's a holdout. If 
you can't determine if there's a holdout, why would you issue 
the injunction?
    Mr. Issa. The comment of diplomacy was used. I appreciate 
that, serving on the Foreign Affairs Committee, but let me 
characterize a question for a moment. The most valuable 
diplomacy the United States has is probably immersed over in 
the Department of Commerce, not the Department of State. Is it 
fair to say that China's unfair activities that have been 
outlined today and Britain and others' desire to have their 
courts make global decisions, and this idea that you can be 
banned hypothetically from seeking any relief elsewhere--all 
those would be offset by U.S. diplomacy that simply said, you 
want access to our market; those rules are not acceptable. Is 
that a fair approach for the new administration to look at, 
that access to our market is so valuable that all these 
activities that we see as unfair should be negotiated in light 
of access to our economy?
    Anyone disagree with that? Dr. Copan?
    Mr. Copan. Yes, let me comment. I think these are very, 
very important points that you're raising. I do believe that 
the process that the U.K. courts have utilized to be very 
thoughtful in their analysis actually provide a really positive 
example for the United States with the United Kingdom as a 
close ally and partner. So, I think rather than--
    Mr. Issa. Hold on a second. You are saying that a Federal 
judge, otherwise known as somebody who thinks he is God, should 
simply say we are going to make a decision for the whole world 
even though the Constitution gives him no such power, and that 
this would be good if we mirrored what Britain has done, on at 
least a few occasions?
    Mr. Copan. I'm talking about the thoughtful approach of 
coming to judgment.
    Mr. Issa. My Article III judges are thoughtful. The 
question is more a matter of jurisdiction and sovereignty. So, 
Mr. Baker, you have operated in all these areas. I know it is 
frustrating to have 200 countries, each of which asserts its 
own sovereignty, but is it fair to say that something between 
we will make a decision for the world and then penalize you if 
you try to go to another country and seek remedy different 
there and the idea that there is only standard? That is really 
what global negotiations is about, is to try to cooperatively 
find it, not find it based on the decision of one judge, no 
matter how thoughtful.
    Mr. Baker. Patents have regional boundaries. There's no 
doubt about that. A U.S. patent is valid in the U.S., and no 
place else. If there's going to be an exception to that rule 
relative to licensing, it either comes from the parties that 
say we agree to a global license coming out of a U.S. court, or 
it can be by the U.S. Government, or through diplomacy striking 
a negotiation where you find a broader than the regional 
application for a patent.
    Mr. Issa. Now, there was one point brought up early on, and 
it was the fact that if I am facing this--I love holding up my 
Chinese patent. It is small and worthless. If I am in a Chinese 
court, in nine months I am going to be through my entire appeal 
process.
    Is that not true, Mr. Cohen? If I am in a Chinese court, 
but I am an American patent holder, do I get done in nine 
months or is that a one-way street currently?
    Mr. Cohen. By law it's a one-way street, which is to say 
that the mandatory timeframes for civil litigation including 
the appeal in China do not apply if it's a foreign-related 
case. What is a foreign-related case is an undefined term, but 
I think your appearance from the United States in a Chinese 
court would clearly be a foreign-related case.
    Cases will get drawn out frequently because they're afraid 
of the diplomatic context, the political context, or perhaps 
for other reasons, but they do get drawn out for foreigners.
    Mr. Issa. So, in closing, and there will be a lot more 
questions that you have kindly said you will answer for the 
record, if there was one thing in our dealing with China's 
access and China's implementation of their patents that you 
would want us to look at for next year would be--I guess it is 
two things. One is to find a way to match that nine months as 
best we can in the U.S. to bring some level of parity, if at 
all possible.
    Then, first--and I know the ITC was mentioned; we will 
leave that where it was for now. Second, deal with the lack of 
reciprocity in that--you have said it very well, Mr. Cohen, in 
the U.S. we do not look at the country of origin in an Article 
III court case, or even at the PTO. China does. If that 
continues then we will never really--will get justice between 
the two. It would be like the old days with the Russian judges 
at the Olympics.
    Anyone see that as not one of the key areas that we have to 
work to change?
    Any last closing remarks from any of the panelists before I 
send you off with your homework in writing? With that--Yes?
    Mr. Baker. I would just add that my comments today were for 
small-and medium-sized companies that represent 90 percent of 
the companies that are building out IoT. They're not large 
companies. Much as you started with your technology and then it 
grew into a larger entity, that's the type of customer that we 
have. If you license us and there is a SEP-FRAND relationship 
that can be struck, you're licensing 2,000 people--or 2,000 
companies at a time that will never pay royalties to a major 
patent holder if you don't license through us. If you want to 
go to the end product, the money won't be there in a U.S. court 
to sue them and you're leaving that money on the table.
    Mr. Copan. If I may add something?
    Mr. Issa. Yes.
    Mr. Baker. It's not fair.
    Mr. Issa. Please.
    Mr. Baker. I really appreciate the opportunity to join you 
today. The important focus on small- and medium-sized 
enterprises as well, because these intellectual property 
enforceability issues are existential for these companies, the 
ability to continue to operate profitably on a global basis 
where we see an uneven playing field.
    The United States as a free market economy also has great 
benefits to lead the world by example and to take an approach 
that is not regulatory-forward but enables the free market to 
really work, and then to work diplomatically and, to the point 
that was raised earlier, with economic force to ensure that 
China does pay attention.
    Mr. Issa. Thank you. Yes?
    Mr. Cotter. Just briefly, I would just urge the 
Subcommittee to be mindful that whatever measures Congress may 
see fit to pass to strengthen patent rights--they may see that 
as a desirable thing to do to respond to China or to increase 
incentives for innovators, but be mindful that those--some of 
those provisions, some of those actions could potentially 
backfire against other U.S. companies that need access to 
technology that should not be excluded from the market, that 
should not be threatened by patent assertion entities wrongly. 
I think there needs to be a balance.
    Mr. Issa. Thank you. As we conclude, I would like to yield 
to the Ranking Member if he has any end-of-year comments, 
particularly if they are related to the Ranking Member of the 
Full Committee who has appeared for the last time in that 
particular role here today.
    Mr. Johnson. Well, the gentleman is being quite judicious 
today and I shall adopt that same stance toward Ranking Member 
Jerrold Nadler, who has been Ranking Member or Chair of this 
Committee I believe for 15 years. He is stepping down from that 
position as of the 119th Congress. He will become just a 
singular valued Member of our Committee and Jamie Raskin will 
assume the Ranking Membership responsibilities.
    So, at this time on behalf of all the Members of the 
Judiciary Committee on this side of the aisle I want to thank 
Jerry for his service, recognize the great service that he has 
rendered, wish him the best as we all move forward together.
    I thank once again the Chair of this Subcommittee, my 
friend and partner Darrell Issa, for the value that he has 
brought to the Committee at large and his leadership of this 
Subcommittee.
    Once again, happy holidays to everyone and thank you all 
for your very great testimony today. Thank you.
    Mr. Issa. Thank you.
    Mr. Johnson. I see a Member, a former Member of Congress, 
Ed Perlmutter, who is in the House today. I want to shout him 
out, recognize him.
    Mr. Issa. With his Christmas tie on.
    Mr. Johnson. Yes, that is right. I see Jamie Simpson who is 
here, former lead staffer on the Committee. Also, David 
Lachmann, a former Committee staffer is here as well. So good 
to see you all.
    Mr. Issa. Thank you. I will note for the record that 
Ranking Member Nadler has expressed that he will continue to be 
on this Subcommittee and has been both Chair and Ranking Member 
of this Subcommittee additionally over the years.
    This concludes today's hearing, and I want to thank all our 
witnesses for what they have done for us here today and what 
they have agreed to do in the next five days to come.
    Without objection, all Members will have five legislative 
days in which to submit additional written questions for the 
witnesses and additional materials for the record.
    Without objection, for the year we stand adjourned.
    [Whereupon, at 11:42 a.m., the Subcommittee was adjourned.]

    All materials submitted for the record by Members of the 
Subcommittee on Courts, Intellectual Property, and the Internet 
can
be found at: https://docs.house.gov/Committee/Calendar/ByEvent 
.aspx?EventID=117764.