PK Comments on FTC Proposed Settlement with MPHJ
PK Comments on FTC Proposed Settlement with MPHJ
PK Comments on FTC Proposed Settlement with MPHJ

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    In re: MPHJ Technology Investments, LLC,
    et al.—Consent Agreement
    File No. 142 3003
    79 Fed. Reg. 67,159


    Attn: Office of the Secretary
    Federal Trade Commission
    600 Pennsylvania Ave. NW, Suite CC-5610 (Annex D)
    Washington, DC 20580

    Public Knowledge respectfully submits the following comments in response to the Proposed Consent Agreement regarding MPHJ Technology Investments, LLC et al., dated November 13, 2014. Public Knowledge is a nonprofit organization that focuses on the intersection of technology and policy. PK has previously discussed these matters with FTC counsel and also filed related comments in the FTC’s proceeding on its Section 6(b) study on patent assertion entities.

    The Federal Trade Commission is to be applauded for taking action against this most egregious example of anti-consumer practices by MPHJ Technology Investments and its affiliates. As the FTC itself has recognized, the Commission’s statutory authority cannot solve all of the abusive practices attendant to patent assertion, such as frivolous, protracted litigation involving questionable patents. But when it comes to fraudulent threats of patent litigation directed at technology consumers, as occurred here, the Commission acts fully within its central mission, and it should forcefully and authoritatively send a message that such practices are not tolerated by U.S. law.

    The following comments suggest how the FTC may further strengthen the proposed consent order to protect these important consumer protection interests.