Throughout the year, our policy team submits filings with government bodies worldwide to advocate for a regulatory environment that inspires and rewards innovation. From issues around regulating artificial intelligence to digital trade, our team is ACTive on a wide range of topics that could have a positive or negative impact on our small business members driving the app economy. Below is a roundup of our filings from around the globe this past month.
Entity: BIS
Jurisdiction: United States
Summary: The App Association responded to the Department of Commerce’s Bureau of Industry and Security’s request for comments regarding information and communications technology and services that are integral to unmanned aircraft systems. The App Association emphasized that unmanned aircraft systems are a part of the broader digital economy, making use of third-party applications and services. The App Association cautioned that, while focusing on security, BIS’s rules could possibly have the effect of harmful digital trade barriers.
Filed: March 3, 2025
Entity: USITC
Jurisdiction: United States
Summary: The App Association submitted comments to the International Trade Commission in response to the commission’s call for comments on certain video capable electronic devices and comments. The App Association urged careful consideration of U.S. small businesses that develop Internet of Things (IoT) devices, emphasizing the importance of not excluding standard-essential patents in video coding that are essential for small businesses and job creation in the growing IoT space.
Filed: March 3, 2025
Entity: USTR
Jurisdiction: United States
Summary: The App Association submitted comments to the United States Trade Representative to assist in reviewing and identifying unfair trade practices and initiating necessary actions to investigate harm from non-reciprocal trade arrangements. App Association member companies face challenges entering new markets due to trade barriers from laws, regulations, and policies. The comments detail specific examples in numerous countries of trade barriers of concern.
Filed: March 11, 2025
Entity: USITC
Jurisdiction: United States
Summary: The App Association responded to the International Trade Commission’s call for comments on certain video capable electronic devices. The comments strongly urged the USITC to act consistent with, and to build upon, existing global consensus guidance providing clarity on what a fair, reasonable, and non-discriminatory (FRAND) commitment in the standard-essential patent context means. The filing addresses the Commission’s questions 5, 6, and 10, all relating to the FRAND licensing commitment.
Filed: March 13, 2025
Entity: NSF
Jurisdiction: United States
Summary: The App Association submitted its views in response to the Technology Research and Development National Coordination Office’s request for information to inform the development of an Artificial Intelligence (AI) Action Plan. The App Association agreed that making the Administration’s AI Action Plan is a timely and necessary foundation for future government AI policies, providing 10 principles that the App Association considers to be essential in the creation of the plan.
Filed: March 14, 2025
Entity: DG GROW
Jurisdiction: European Union
Summary: The App Association submitted comments to the European Commission’s consultation on its Startup and Scaleup Strategy. The App Association addressed Europe’s increasingly complex regulatory landscape that has created significant burdens on small businesses, presenting specific hurdles faced by startups and advocating that a transparent and fair standard-essential patent framework is needed to keep innovation and attracting investment in Europe’s leadership in the global tech economy.
Filed: March 17, 2025
Title: Comments from ACT | The App Association re: Proposed Amendments to DIFC Legislation
Entity: DIFC
Jurisdiction: United Arab Emirates
Summary: The App Association submitted views to the Dubai International Financial Center Authority in response to its request for public comment on its proposed amendments to several data protection-related laws and regulations via the DIFC Amendment Law. The App Association advocated for the consideration of consistency, protection against unauthorized access, path to compliance, and proper enforcement mechanisms in the amendments to data protection laws and regulations, explaining importance for each principle.
Filed: March 26, 2025
Title: ACT | The App Association Comments to the European Patent Office on the 2026-2027 workplan
Entity: EPO
Jurisdiction: European Union
Summary: The App Association responded to the European Patent Office’s online public consultation as they prepare their second biennial work plan for its Observatory on Patents and Technology. The App Association ranked the 10 proposed topics and suggested the inclusion of impacts of regulatory devolvement on small and medium-sized enterprises and the intersection of IP protection and digital platforms as other topics that should be considered.
Filed: March 27, 2025
Title: ACT | The App Association Comments to the AI Office on the third draft of the GPAI Code of Practice
Entity: EU AI Office
Jurisdiction: European Union
Summary: The App Association completed a survey in response to the third draft general-purpose AI Code of Practice. Stating first that the third draft improves structure and clarification, the App Association expressed concerns over the proposed approach to compliance flexibility, explaining how the current exemption framework remains insufficiently defined and risks unintended consequences.
Filed: March 27, 2025