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: United States Trade Representative (USTR)
Jurisdiction: United States
Summary: ACT filed comments in response to USTR’s review of notorious markets for counterfeiting and piracy. The comments highlighted intellectual property (IP) rights violation scenarios, including illegally reusing app content, “brandjacking,” and government-mandated transfer of IP to gain market access. The comments also urged USTR to consider the role of some jurisdictions’ platform competition laws, such as Europe’s Digital Markets Act (DMA), in weakening the ability of platforms to enforce IP protections.
Filed: October 1, 2025
Entity: USTR
Jurisdiction: United States
Summary: ACT responded to USTR’s request for comments concerning Russia’s implementation of its commitments under the World Trade Organization (WTO). ACT provided its general digital trade principles and highlighted examples of Russia failing to follow them, such as by imposing data localization requirements, mandating weakening of technical protection mechanisms such as encryption, and manipulation of the domain name system.
Filed: October 1, 2025
Entity: Supreme Court of the United States
Jurisdiction: United States
Summary: ACT filed an amicus brief in the Epic v. Google case in support of Google’s application for a stay of remedies pending a decision on the merits. The brief raised concerns about the lower court judge’s proposed remedies in this case and how they would harm app developers who distribute their products and services on the Google Play store. Of particular concern is the remedy that would make the entire Play store catalog available to third-party stores, raising significant risks for privacy, security, and IP protection.
Filed: October 1, 2025
Entity: European Commission
Jurisdiction: European Union
Summary: ACT submitted comments in response to the European Commission’s consultation on the European Innovation Act. The comments argued that the Act represents an opportunity to improve Europe’s capacity to support startups and innovation by focusing on access to finance, access to talent and skills, access to infrastructure, and a strong IP framework.
Filed: October 3, 2025
Entity: UK Intellectual Property Office (UKIPO)
Jurisdiction: United Kingdom
Summary: ACT filed comments in response to UKIPO’s consultation on standard-essential patents (SEPs). The comments urged UKIPO to adopt a number of reforms to improve SEP policy in the UK, including the development of an aggregate royalty benchmark, improved transparency, and mandatory SEP holder disclosures in licensing demands. The comments also provide an in-depth analysis of the current policy challenges surrounding SEPs and the fair, reasonable, and non-discriminatory (FRAND) commitment.
Filed: October 7, 2025
Entity: European Commission
Jurisdiction: European Union
Summary: ACT provided feedback to the European Commission’s consultation on the Digital Omnibus, a legislative package dealing with a number of topics related to the digital economy. The feedback outlined current challenges facing small and medium-sized businesses operating in Europe’s digital sphere and proposed improvements such as harmonizing risk management requirements, ensuring predictable and proportionate application of the AI Act, streamlining compliance with an array of digital rules and regulations, simplifying the European Digital Identity framework, and focus more on whether challenges could be met by enforcing current laws rather than stacking up new, sometimes overlapping proposals.
Filed: October 14, 2025
Title: Comments of ACT | The App Association, Draft FTC Strategic Plan for FY 2026-2030 (FTC-2025-0660)
Entity: Federal Trade Commission (FTC)
Jurisdiction: United States
Summary: ACT submitted comments to the FTC regarding its draft strategic plan for fiscal years 2026-2030. The comments urged the FTC to consider policy recommendations including focusing enforcement actions on demonstrated harms, addressing harmful anticompetitive SEP abuses, and rolling back the Biden Administration’s burdensome updates to merger guidelines and notification rules.
Filed: October 17, 2025
Entity: Brazilian Institute of Industrial Property (INPI)
Jurisdiction: Brazil
Summary: ACT submitted comments to INPI in response to its draft guidelines for the examination of patent applications related to artificial intelligence (AI). The comments provide examinations of the impact of AI on the prior art and inventorship analyses and recommended that INPI should take a more flexible approach to eligibility and AI model, training, and data claims, take a less prescriptive approach to disclosure requirements, and develop further guidance governing the responsible use of AI tools by parties and practitioners.
Filed: October 17, 2025
Entity: European Commission
Jurisdiction: European Union
Summary: ACT submitted feedback to the European Commission regarding the draft revised Technology Transfer Block Exemption (TTBE) regulation and draft revised Technology Transfer Guidelines. The feedback supported general updates and pro-competitive safeguards but recommended that the Commission should clarify that the Safe Harbour program requires technology pools to assume licenses IP obligations, that the Commission should prohibit use-based pricing by patent pools, and that it should not engage in litigation coordination that facilitates anticompetitive holdup.
Filed: October 23, 2025
Entity: European Commission
Jurisdiction: European Union
Summary: ACT submitted feedback to the European Commission in response to its consultation on the Digital Fairness Act. The feedback recommended that the Commission focus on streamlining the EU’s digital rules rather than creating more overlapping requirements. ACT’s comments went into greater detail on how new rules around targeted advertising, interface design, and digital contracts and subscriptions would be duplicative, as these topics could be addressed by enforcing existing laws.
Filed: October 24, 2025
Title: Comments of ACT | The App Association Regarding the Department of Homeland Security Notice of Proposed Rulemaking on the Weighted Selection Process for Registrants and Petitioners Seeking to File Cap-Subject H-1B Petitions (DHS Docket No. USCIS-2025-0040)Entity: Department of Homeland Security
Jurisdiction: United States
Summary: ACT submitted comments to the Department of Homeland Security U.S. Citizenship and Immigration Services (USCIS) in response to its notice of proposed rulemaking on the establishment of a weighted selection process for those seeking to file cap-subject H-1B petitions. The comments urged USCIS to reconsider, as its proposal would limit the ability of small businesses and startups to access an essential talent pool.
Filed: October 24, 2025
Entity: U.S. Senate Committee on the Judiciary
Jurisdiction: United States
Summary: ACT submitted a statement for the record to the Senate Judiciary Committee for its hearing entitled, “Pressure Cooker: Competition Issues in the Seed & Fertilizer Industries.” The statement described the role of standards in innovation in fields such as precision agriculture and explained how small and medium-sized businesses are disproportionately harmed by abusive licensing practices in technical standards.
Filed: October 27, 2025
Entity: White House Office of Science and Technology Policy (OSTP)
Jurisdiction: United States
Summary: ACT submitted comments to OSTP in response to its request for information on identifying federal regulations that hinder AI innovation. ACT’s comments incorporated its AI policy principles, including harmonizing and coordinating approaches to AI, modernizing privacy and security frameworks, the importance of standards and SEP policies, education, and IP protection. The comments also included ACT’s AI Roles and Interdependencies Framework.
Filed: October 27, 2025
Title: ACT | The App Association responses to Ofcom (UK) Consultation on Online Harms
Entity: Ofcom
Jurisdiction: United Kingdom
Summary: ACT responded to Ofcom’s survey as part of its consultation on online harms. ACT highlighted the importance of preserving encryption for user privacy and security and consumer trust and warned against adopting policies that would undermine these important data safeguards.
Filed: October 27, 2025
Entity: U.S. Court of Appeals for the Federal Circuit
Jurisdiction: United States
Summary: ACT filed an amicus brief in support of neither party in the case Roku v. Dolby, et al. The brief shined a light on the importance of predictable and balanced FRAND licensing principles for SEPs for the ecosystem of small business and innovators who rely on them and warned of the anticompetitive outcomes that could occur if patent pools are not subjected to court-enforceable FRAND commitments.
Filed: October 27, 2025
Entity: United States Trade Representative
Jurisdiction: United States
Summary: ACT filed comments to USTR as part of the production of the annual National Trade Estimate, a document that, in part, summarizes the trade barriers encountered by American businesses when engaging in markets around the world. ACT’s filing identified 95 distinct trade barriers across 32 countries, and included ACT’s general digital trade principles, which include enabling cross-border data flows, prohibiting data localization requirements, prohibiting duties and taxes on digital content and services, preventing source code transfer as a condition of market entry, preserving strong encryption, protecting IP, and avoiding the misapplication of consumer protection and competition laws to emerging technology markets.
Filed: October 30, 2025