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Testimonies & Filings

September 26, 2022

Comments to the FTC on Updating the Endorsement Guides

Impactful revisions to the “Guides Concerning the Use of Endorsements and Testimonials in Advertising” should promote innovation, protect consumers, and capture how endorsement advertising has changed since 2009, with a focus on social media, consumer reviews, and advertising disclosures.

September 23, 2022

Comments to the Federal Railroad Administration Regarding Train Crew Size Safety Requirements

The proposed rule, while written to suggest that it will enable rail innovation and the operation of less-than-two-person crews, will in fact likely stifle continued rail innovation and limit any expansion of one-person crews and the economic productivity that generates.

September 22, 2022

Testimony Before the DC Committee on Government Operations and Facilities on the “Stop Discrimination by Algorithms Act of 2021”

In testimony before the DC Committee on Government Operations and Facilities, ITIF vice president Daniel Castro, director of the Center for Data Innovation, argued that the Stop Discrimination by Algorithms Act of 2021 is well-intentioned but ultimately misguided.

August 19, 2022

Comments to the Department of Energy on Vehicle Integrated Photovoltaics

Although vehicle-integrated photovoltaic (VIPV) and vehicle-added photovoltaic (VAPV) strategies could in principle complement policies that impact the transportation sector and have climate benefits, the likelihood of breakthroughs that significantly improve upon current VIPV and VAPV products is low.

July 27, 2022

Comments to the FCC Regarding Efficient Use of Spectrum Through Improved Receiver Interference Immunity Performance

The Commission should incentivize voluntary, industry-led standards and take a forward-looking approach to the future interference environment by establishing a clear framework for adjudicating interference claims in the face of differential receiver quality.

July 6, 2022

Comments to the European Commission Regarding Regulation of Plants Produced With “New Genomic Techniques”

The European Commission is considering how to regulate products derived from gene editing and has solicited public comment, but the Commission missing a golden opportunity—again.

June 30, 2022

Comments to Australia’s Department of the Prime Minister and Cabinet Regarding the National Data Security Action Plan

Including data localization in its National Data Strategy would be a critical misstep that would undermine what Australia is otherwise working to achieve at home and globally in terms of digital policy.

June 8, 2022

Comments to the UK House of Commons Public Bill Committee Regarding the UK Online Safety Bill

The UK’s Online Safety Bill fails to preserve users’ rights to legal free expression and privacy in the digital space and will actually exacerbate privacy and content moderation concerns online.

May 24, 2022

Comments to the European Commission on the Cyber Resilience Act Initiative

The Commission should avoid maintaining the status quo or pursuing broad horizontal regulation.

May 23, 2022

Comments to the National Telecommunications Information Administration Regarding Competition in the Mobile App Ecosystem

The Biden administration should withdraw its support of S.2710 at least until the NTIA provides evidence of alleged anticompetitive conduct in a failing mobile apps market through its study. Until then, support for the S.2710 is rushed and undermines the effectiveness of the fact-finding exercise carried out by the NTIA via its RFC.

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