We could use better guidance on Bayh-Dole

I like how Eric Guttag goes after legal ideas.  I appreciate the way he digs into things, and his willingness to acknowledge when he needs to change his point of view.  Some time ago, he posted an excellent discussion of the FilmTec decision in the context of Stanford v Roche, and just how far the magic of a “present assignment” ought to go.   It’s worth the read.  Guttag emphasizes the importance of getting at the fact set in S v R, and this in itself appears to be rather difficult to do.   The question that burns throughout S v R is how to size up the status of assignments at the time that Stanford files its patent application.  The CAFC looks at it and goes, “there’s only one assignment, and that’s to Cetus”.  That assignment was the present assignment embedded in the Cetus Visitor’s Agreement.  If that assignment fails, then Stanford’s later assignment becomes operative, and we are back to other issues, such as whether Stanford’s patents are even valid.

However, with the decision we get a strange mix of responses.  On the one hand, we have questioning of the nature of present assignments, and in particular of the FilmTec decision, which features such an assignment.  There’s plenty of practice that indicates that there are instances of well formed present assignments, such as in some publication agreements.  If the asset to be created is clearly delimited, why should not an author or inventor be able to obligate his or her expectant rights in a work of authorship or invention?  The question, though, is whether there’s something magically different about “hereby assign” over “will assign”.   But here’s the rub: if a promise to assign is as good as the “hereby assign” to transfer title, then Cetus is still holding a valid agreement (which used *both* forms).   If, however, “hereby assign” means nothing more than “I really, really do promise to assign in the future”, then one would have to follow up with an actual written assignment specifying the invention. Continue reading

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AUTM, the clueless inventor-loathing organization

. . . AUTM, of course, is already opposed, using their usual argument that everyone else is a stupid idiot and only AUTM has the intellectual capacity to navigate such “incredibly complex and nuanced matter.”

{/vent} AUTM is the organization, remember, that couldn’t get Bayh-Dole right after thirty years of trying. AUTM opposed Kauffman Foundation’s call for discussion of ways to improve technology transfer by restoring the invention agent marketplace that Bayh-Dole anticipated would operate. Check out AUTM’s “No Free Agency resource center.” Here’s their featured graphic:

AUTMnofree

They oppose the idea of public *discussion*! AUTM prevented IP Advocate from simply informing its members about past and current lawsuits brought by universities against faculty inventors. AUTM folks of course opposed my call for changes in light of Stanford v Roche. Instead, what are you AUTMites off doing? Helping backfill the loss of “federal law requires assignment” with goofball “present assignments” that make hash of policy, IP practice, and innovation alike? Whenever there is a call for diversity, change, or innovation in research innovation management, you can be sure AUTM will be there with fallacious arguments, deceptive metrics, and the insinuation that no-one else on the planet should be allowed to speak to the interests of IP policy, university research, or innovation allied with that research. Continue reading

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AAUP on University-Industry Relationships

The AAUP has released a working draft of a set of principles for university-industry relationships.  The text lays out a set of recommendations with regard to intellectual property, research contracting and strategic partnerships, and conflict of interest.  The AAUP is looking for public comment, after which it will revise the draft and release it in final form.  The AAUP describes a central feature of the report:

The report urges that faculty governing bodies have greater authority over the principles regulating outside funding and over the disposition of inventions derived from faculty research, but it is by no means exclusively an assertion of faculty rights. It specifies—and emphasizes—the responsibilities that must come with outside funding, among them the public disclosure of all financial conflicts of interest. Not all will readily embrace those responsibilities, but the time has surely come when every institution needs to debate and consider them.

The Scientist has a brief story on the report here.   It’s time that there is a different sort of discussion about IP, contracting, licensing, and the purposes of university scholarship.  The AAUP has just stepped up to play an important role in reminding folks that academic values really do matter.

AUTM, of course, is already opposed, using their usual argument that everyone else is a stupid idiot and only AUTM has the intellectual capacity to navigate such “incredibly complex and nuanced matter.”  Sorry to break it to you, AUTM folks, but you are now pretty much the dullest tool in the innovation shed.

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Berlin contracts and Bayh-Dole

Germany has produced its own version of template agreements for research between universities and industry, called the “Berlin contracts.” There is even an English translation that makes for interesting reading. German law is also interesting because in addition to patent law they have the German Employees Invention Act (EIA).  Under the EIA, inventions are classified as “service” or “free.” Here is a good explanation of the differences:

Service inventions are those made during the term of employment which either result from the employee’s activities in the business or public service, or are significantly based upon the experience or activities of the business or public service. In practice, most inventions made in the course of the employment relationship are service inventions. All other inventions are free inventions which are owned by the employee but subject to the limitations of §§ 18 and 19, namely that the employee inventor has an obligation to notify the employer of the invention and offer the employer at least a non-exclusive license, if it wishes to exploit the invention.

The EIA establishes a requirement that the employer who retains a service invention made by an employee must compensate the employee for the invention. The EIA also provides a protocol for how this compensation is determined. There are two steps. In the first, the value of the invention is determined using one of three approaches: Continue reading

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Invention use or patent use, which will it be?

A while back I looked at the Lambert agreements.  These are model agreements developed in the UK that aim to normalize research arrangements between universities and companies.   My review of them argued that they were a bit sloppy and inconsistent, handled IP in an odd way, and at the broadest level did not appear to have much at all to do with innovation.   Industry-university research contracting gets this way when the primary issue is who owns the IP, rather than what is to be done with the subject matter the IP attaches to.

Presumably, if the subject matter is new, then the point of having it is to use it.   That works if it makes sense to use it.   Sometimes it is not as easy as that–an invention can be an idea that would cost a lot to turn into a working prototype, or requires a number of other things to be done before it can be used, such as if the invention is a step in process that requires two or three other inventions.   Sometimes an invention is good as a research tool.  And sometimes an invention is one of a number–maybe 30, maybe 50, maybe 100–variations on ways to accomplish something, and it’s not clear whether Way 1 is going to be as good as Way 16 or Way 42.  Thus, even if use is the goal, use is not always possible, or even if it is, there may be delays in arranging financing or getting other things in place.

One older study (cited here, p. 12) of a number of successful inventions in Germany reported that the shortest time from invention to commercial exploitation was six years.  And these were ones a company had made, claimed, and wanted.  Continue reading

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IP Governance or IP Management?

After Bayh-Dole was passed, university administrators got the idea that universities had to have policy statements to claim ownership of inventions to comply with Bayh-Dole.  The idea was that “elect to retain title” meant “elect title” which meant “title vests with the university until university administrators elect otherwise”.  This is the “system” that Joe Allen and Birch Bayh are now arguing that they intended to create, and would be a shame to dismantle/replace/change in any way.  I disagree.  Bayh-Dole did not propose the system that is now dominant.  The present “system” itself is a terrible mess that’s trying to get by with spin, narrative fallacy, and confirmation bias.  And it would not be so bad to make some changes, if not to the “system,” which may as good as it is going to get, then to introduce other approaches, to give the system a little competition and see what it is actually made of.  Last I heard, competition was good for innovation.  I haven’t heard the same thing about monoculture, central administrative control, or compulsory ownership policies.   Funny, one would think that folks dealing with innovation would have gotten the memo.

That said, the Stanford v Roche verdict is rather remarkable, as it overturns a 30-year  scheme to assert institutional ownership of research inventions based on a wrong interpretation of Bayh-Dole–and this situation would not have been made so clear had not AUTM, WARF, and MIT been so intent on seeing Stanford’s litigation against Roche escalate.   In the wake of Stanford v Roche, I have not seen any university administration go, “Gosh, we sure got that wrong” and revise or withdraw policy or guidance statements that claim that Bayh-Dole requires university ownership of inventions.   Instead, university administrators are actively seeking new ways to claim ownership of faculty inventions.  If Bayh-Dole won’t do any more, then surely there is another way to get there.

The Bayh-Dole Act was passed in an environment in which only a few universities operated in-house licensing shops–Stanford and MIT, notably.  Continue reading

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Reef or Trench? University research and open access to results

There is a petition on-line asking the President to require the posting of “published results” of federally funded research on-line for public access.   A story about it is here.  The effort is led by John Wilbanks, who previously led Science Commons and now is a senior fellow with the Kauffman Foundation, where he is continuing his public advocacy for open science. In general this is a good thing.  If you want to sign the petition, it’s here.

If one focuses on university research, perhaps the first question is why such a petition is even necessary.    OMB Circular A-110 (2 CFR 215) is the primary regulatory document that comes into play.  It sets up a government license (.36(a)) to publish “any work that is subject to copyright” developed or acquired under a federal award, and to permit others to do so.  A similar right is established for data (.36(c)).  Furthermore, if federally funded work is (i) published and (ii) becomes the subject of rule-making with the force of law, then the backing data is required to be disclosed if requested under FOIA (.36(d)).   “Data” is defined as “recorded factual material commonly accepted in the scientific community as necessary to validate research findings”.  The definition excludes “preliminary analyses, drafts of scientific papers, plans for future research, peer reviews, or communications with colleagues” as well as “physical objects” and “trade secrets, commercial information, materials necessary to be held confidential by a researcher until they are published, or similar information which is protected under law” and “personnel and medical information”.

Why does one need (d) when one already has (a) and (c)?  Continue reading

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Coolangatta IP

Traditional knowledge encompasses the information possessed and developed within a community.  Such knowledge arises and is used to inform the activities of the community–it is “traditional” in this way.  The authors of a AAAS handbook, in a discussion of TK, point out how intellectual property rights–statutory rights established or recognized by a state, along with trade secrets–may conflict with TK:

Intellectual property rights should guarantee both an individual’s and a group’s right to protect and benefit from its own cultural discoveries, creations, and products. But Western intellectual property regimes have focused on protecting and promoting the economic exploitation of inventions with the rationale that this promotes innovation and research. Western intellectual property law, which is rapidly assuming global acceptance, often unintentionally facilitates and reinforces a process of economic exploitation and cultural erosion.

Often, the conventional statutory formulations of patents, copyrights, and the like are at substantial odds with TK.  One might consider IP, in this regard, to be a tool of disruption–breaking apart existing activities in favor of ones sanctioned by the state, which is indifferent to private or community approaches to knowledge, expression, invention, and education. Continue reading

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More Evidence in the Wild

Here is another example in the wild of the mischaracterization of Bayh-Dole.  This is a document that offers a “Brief Guide to Intellectual Property in a University Context”.   My point is to document how Bayh-Dole has been represented by university officials.  I expect the document to come down soon after I’ve posted this note, so if the link to it is broken, that’s a good sign.

After defining “intellectual property” to include patents, copyrights, trademarks, and trade secrets, we get this under “Key Laws, Regulations and Policies Regarding Intellectual Property”:

A. The Bayh-Dole Act (Public Law 96-517, 98-620)
· Intellectual property that results from research funded by the Federal Government is owned by the institution that performs the research.
· The Federal Government retains limited rights to such IP, including, but not limited to:
o Non-exclusive right to use for government purposes
o Right to claim ownership if ownership is waived by institution
o Right to claim ownership if commercialization does not proceed fast enough

This statement gets it wrong multiple ways.  I will highlight a few. Continue reading

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The BioBrick BPA and Group Dynamics

The BioBricks Foundation supports a repository of “parts” for use in synthetic biology. It has implemented an interesting two-part arrangement called the BioBrick Public Agreement or BPA. This agreement aims to manage the interests of contributors and users of the repository and is worth reviewing. The BPA establishes what BBF calls “open wetware”–making synthetic biology parts available for use while minimizing the threat of IP claims and the overhead of bilateral licensing.

Bilateral negotiations are, in a deep cultural sense, a good thing. When two people meet, they trade, and to trade, they negotiate their interests. Trades this way may not be “fair” in the big picture of relative gains, but even so, such trades may be appropriate, beneficial, and satisfying to those involved. However, in the world of trading conventions, especially in the context of intellectual property, one encounters complexities that make it next to impossible for individuals to conduct their own negotiations. These complexities come about in two categories. First, there are the details of IP–it’s easy to get these wrong, forget important stuff, and generally create arrangements that won’t hold up later, if there is a need to rely on the written agreement for an answer. Second, there is the effect of many deals that become related. If one is doing only a single, independent deal, then have at it.  But if one needs to conduct ten or fifty such deals before having access to sufficient assets to do anything useful, then having each deal be custom means quickly that deals will be incompatible with other deals–each one with its own requirements. Deals easily then may lack “interoperability” and doing one deal may foreclose doing the next deal.

Thus, to operate at scale, to build platforms and libraries of technology resources, public licenses provide a way to normalize a set of transactions so that they are interoperable. Continue reading

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