Always Be Filing: ACT | The App Association Filing Activity December 2024

 

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.

Title: Epic v. Google Amicus Brief

Entity: 9^th Circuit Court of Appeals

Jurisdiction: United States

Summary: The App Association filed an amicus brief in response to proposed remedies in the Epic v. Google case, including requiring Google to make the Play Store’s entire app catalog available to third-party stores. The App Association argued that these remedies would have negative impacts on app developers and would in fact undermine competition in the app store market.

Filed: December 4, 2024

 

Title: Existing Awards and Recognition Programs for Standards Development and Best Practices for Standards Workforce Development in Support of the Implementation of the United States Government National Standards Strategy for Critical and Emerging Technology (USG NSSCET)

Entity: National Institute of Standards and Technology (NIST)

Jurisdiction: United States

Summary: The App Association provided feedback to NIST’s draft Implementation Roadmap for the USG NSSCET, including suggesting that NIST clarify the private sector’s leadership role in the program, avoid public/private sector duplication of efforts in pre-standardization activities, support small and medium-sized businesses, and address standard-essential patent (SEP) abuse.

Filed: December 9, 2024

 

Title: CNMC Study on Cloud Services

Entity: Comisión Nacional de los Mercados y la Competencia (CNMC)

Jurisdiction: Spain

Summary: The App Association responded to CNMC’s request for information into Apple’s App Store practices, clarifying that App Association members had largely not experienced a number of alleged harmful actions. The App Association argued that the relationship between app developers and app stores is symbiotic, and that the competitive integrity of the app ecosystem is being threatened by regulation like the EU Digital Markets Act (DMA).

Filed: December 10, 2024

 

Title: Multi-Stakeholder Consultation for Commission Guidelines on the Application of the Definition of an AI System and the Prohibited AI Practices Established in the AI Act

Entity: EU AI Office

Jurisdiction: European Union

Summary: The App Association responded to an EU AI Office survey asking a number of questions about aspects of the AI Act’s definitions and requirements. The App Association’s responses highlighted the overbroad nature of some definitions, the importance of risk-based scaling requirements based on an AI system’s likelihood of harm, and the need for more specificity and less subjectivity.

Filed: December 10, 2024

 

Title: Mobile Browsers and Cloud Gaming Provisional Decision Report

Entity: Competition and Markets Authority (CMA)

Jurisdiction: United Kingdom

Summary: The App Association submitted comments to the UK CMA’s Mobile Browser and Cloud Gaming Investigation Provisional Decision Report. The App Association highlighted concerns about the potential for unintended consequences from CMA’s proposed remedies, including undermining digital security and innovation.

Filed: December 13, 2024

 

Title: Revised Market Studies Information Bulletin

Entity: Competition Bureau

Jurisdiction: Canada

Summary: The App Association filed comments to assist the Canadian Competition Bureau in crafting a new version of its Market Studies Information Bulletin in keeping with recent changes to the Competition Act. In its comments, the App Association provided its general views on the importance of competition policy for small and medium-sized businesses that promotes innovation through predictable, fair, and industry-agnostic regulatory structures and practices.

Filed: December 23, 2024