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Testimonies & Filings

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.

May 6, 2022

Comments to the SEC Regarding Its Proposed Rule on Cybersecurity Risk Management, Strategy, Governance, and Incidence Disclosure

ITIF supports SEC’s efforts to ensure publicly traded companies disclose relevant information on their cybersecurity practices and material cybersecurity incidents, which would enable investors to make more informed decisions, in line with existing SEC disclosure requirements. This type of transparency will not only help investors make more informed decisions, but it should also incentivize companies to adopt cybersecurity best practices.

April 14, 2022

Testimony to the US-China Economic and Security Review Commission on Innovation, Technology, and Intellectual Property

There’s a battle being fought now for the soul of the global trade and economic system; it’s imperative that like-minded nations collaborate to emerge victorious in it.

March 31, 2022

Amicus Brief in the Matter of Epic Games v. Apple

Accepting Epic’s arguments and preventing Apple from continuing to operate its closed mobile ecosystem would eliminate a signature attractive feature of Apple’s products, to the detriment of consumer welfare, competition, and innovation.

March 28, 2022

Amicus Brief in the Matter of State of New York et al. v. Facebook

Facebook’s business justification for limiting platform access for rival app developers was self-evident: It did not want to help them replicate its core functions, nor did it want to share its intellectual property—certainly not for free. That is rational competition, not unlawful anticompetitive behavior.

March 25, 2022

Comments to the US Commerce Department on Incentives, Infrastructure, and R&D for a Strong Semiconductor Industry

ITIF applauds both the Biden administration and U.S. Congress for articulating and advancing the Creating Helpful Incentives to Produce Semiconductors (“CHIPS”) for America Act, which has been passed out of the Senate and House in largely similar form in their respective U.S. Innovation and Competition Act (USICA) and America COMEPTES Act.

March 21, 2022

Comments to the U.S. Commerce Department on the Indo-Pacific Economic Framework

Responding to a Commerce Department inquiry into the Indo-Pacific Economic Framework (IPEF), ITIF provided recommendations on global data flows, privacy, and governance; innovation and advanced manufacturing; standards-setting for data, cybersecurity, AI, cloud services, and other new and emerging technologies; the potential for an IPEF climate-change agenda; and using IPEF to launch a joint commercial intelligence forum.

March 16, 2022

Testimony to the Senate Finance Committee on “Prescription Drug Price Inflation”

Expenditures for retail prescriptions have been roughly stable for the past two decades as a share of total U.S. health-care expenditures. Instead of applying broad price controls, policymakers should promote affordability and mitigate out-of-pocket costs for individuals.

March 16, 2022

Comments to the Justice Department and FTC Regarding Merger Enforcement

In revising merger guidelines, antitrust agencies should refrain from embracing the populist narrative that pursues market deconcentration and corporate disintegration at the expense of companies’ innovation, efficiency, and competitiveness.

February 28, 2022

Comments to the U.S. Department of Energy on Industrial Decarbonization Priorities

U.S. industry does do not yet have all the necessary technology to decarbonize while maintaining its competitive edge in manufacturing. Only with continued federal and private investment in low-carbon RD&D will the United States be able to achieve the twin goals of supporting a robust manufacturing sector while reducing and ultimately eliminating emissions.

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