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: Office of Information and Regulatory Affairs (OIRA)
Jurisdiction: United States
Summary: ACT wrote a letter to OIRA requesting that the Office conduct a thorough economic analysis of the U.S. Patent and Trademark Office (USPTO)’s proposed changes to the Patent Trial and Appeal Board (PTAB). These changes would effectively dismantle the PTAB’s inter partes review (IPR) process, which provides a faster and more affordable alternative to district court litigation for patent disputes. ACT’s letter highlighted that the PTAB process has saved billions of dollars and boosted employment, argued that the proposed changes clearly meet the threshold for economically significant regulatory action, and urged OIRA to begin a comprehensive review.
Filed: November 5, 2025
Entity: European Commission
Jurisdiction: European Union
Summary: ACT submitted comments to the European Commission in response to its consultation on the development of the EU Space Act. ACT urged the Commission to ensure that the Space Act promotes fair and open market access for operators regardless of size or location, creates coherence across existing Member State laws and guidelines and EU instruments, avoids incentivizing a focus on compliance rather than innovation, and encourages international alignment with existing global standards and best practices.
Filed: November 7, 2025
Entity: Ministry of Communication, Digital Technology and Innovations (MOC)
Jurisdiction: Ghana
Summary: ACT submitted comments to the Ghana MOC in response to its proposed draft of new competition and consumer protection regulations. The comments included ACT’s detailed report on the real-world functioning of competitive curated online marketplaces and the benefits they provide for small and medium-sized businesses. ACT urged MOC not to adopt industry- or sector-specific competition rules, instead endorsing a flexible, industry-agnostic approach with a harmonized and predictable legal and business environment.
Entity: House of Representatives, Committee on Energy and Commerce, Subcommittee on Oversight & Investigations
Jurisdiction: United States
Summary: ACT submitted a statement for the record to the Committee and Subcommittee for its hearing titled, “Innovation with Integrity: Examining the Risks and Benefits of AI Chatbots.” The statement details ACT’s principles for AI governance, including using existing law that already provides strong consumer protection guardrails, creating a risk-based framework and shared responsibility model, thoughtful design and clear representations to users, modernized privacy and security frameworks, supporting transparency, privacy and mitigation of data bias, and the need to avoid a patchwork of state laws.
Filed: November 17, 2025
Entity: District Court for the District of Delaware
Jurisdiction: United States
Summary: ACT filed an amicus brief in support of Disney in its suit against InterDigital alleging that InterDigital is using its standard-essential patents (SEPs) to violate antitrust laws. The brief argues that small businesses depend on predictable SEP ecosystems; SEP holders systematically evade fair, reasonable, and non-discriminatory (FRAND) commitments through coercive tactics and information asymmetry; and SEP holders that obtain supra-FRAND royalties are anticompetitively abusing their market power. The brief further argues that robust judicial review is necessary to enforce the FRAND bargain and prevent SEP holders from exploiting their market power, particularly against small businesses that lack the resources to challenge excessive royalty demands through litigation.
Filed: November 21, 2025
Entity: Department of Information and Communications Technology
Jurisdiction: Philippines
Summary: ACT filed comments to the government of the Philippines in response to its draft executive order on modernizing the government’s data classification framework. The comments cautioned the Philippines against adopting data localization requirements and underscored the implications of including private entities within the scope of order, which could unintentionally capture a wide range of routine commercial services.
Filed: November 22, 2025
Entity: International Trade Administration
Jurisdiction: United States
Summary: ACT filed comments in response to ITA’s request for information on the establishment of the American AI Exports Program. ACT provided its general principles for digital trade and offered detailed feedback on the proposal, with themes including realistic and meaningful small business participation, not imposing unnecessary burdens in the definitions, not creating barriers for small businesses, and promoting open standards, interoperability, and FRAND-protected innovation.
Filed: November 26, 2025
Entity: District Court for the Western District of Texas
Jurisdiction: United States
Summary: ACT filed an amicus brief in the case Computer & Communications industry Association v. Paxton in support of CCIA’s motion for an injunction to prevent the App Store Accountability Act from taking effect pending further proceedings. ACT’s brief explains how the law would impose direct and onerous obligations on all Texas companies, not just app stores, and underscores the significant new liability the law would create for app developers and businesses with apps due it its interaction with the federal Children’s Online Privacy Protection Act (COPPA).
Filed: November 26, 2025