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Concurrences
Revue des droits de la concurrence
Competition Law Journal
Gil Ohana: Life at the IP/
Antitrust intersection
Interview l Concurrences N° 2-2013
www.concurrences.com
Gil OhaNa
[email protected]
l
Senior Director, Antitrust and Competition - Cisco Systems
Gil Ohana
[email protected]
Senior Director, Antitrust and Competition Cisco Systems
2009-Present
Gil Ohana: Life at the IP/
Antitrust intersection
You have worked as a DOJ trial attorney, in-house antitrust counsel to two tech
firms (HP and Cisco), as well as of counsel at a law firm. What advice do you have
for law firm practitioners and government attorneys about how to manage
the relationship with in-house counsel?
Senior Director,
Antitrust and Competition
Cisco Systems
Being an antitrust specialist in-house provides a helpful perspective on the business
reasons that underlie the decisions we make as a company. Good external counsel,
particularly those who have a long-term and deep relationship with a particular
client, can achieve the same perspective. It is important for both internal and
external advisors to have that perspective, because it helps in situations in which the
best business result may not be to enforce legal rights or extend legal processes to
the greatest extent possible.
2007-2009
Counsel
Wilmer Cutler Pickering
Hale & Dorr LLP
1993-2007
United States Department
of Justice, Antitrust Division
Trial Attorney position followed
by in-house counsel positions
at Hewlett Packard and Cisco
Systems
1993
J.D., Columbia University
School of Law
“As a company, we have been active in efforts
to reform the US patent system”
As to governments, I have never had to educate anyone at the agencies of what
I do as an internal advisor. Enforcement agency staff recognize the role that
internal antitrust advisors can play, both relative to compliance and as sources of
information about how business decisions are made, though some agencies cling to
positions relative to professional privilege that can have the effect of diminishing
the role of internal counsel. I sometimes have greater credibility with enforcement
agencies being in-house; the agencies are less likely to hear me taking inconsistent
positions on behalf of different clients.
Your portfolio at Cisco spans both mergers and IP issues as they relate to antitrust.
From your standpoint, what are the most important and pressing unresolved issues
in each field right now? Do those issues vary across jurisdictions?
As a company, we have been active in efforts to reform the US patent system, in
particular with respect to the time and expense it takes to resolve patent litigation,
the low bar for granting a patent in high technology, and the remedies for patent
infringement. Some of those issues have competition policy aspects, and we
welcome the participation of antitrust enforcement agencies in the United States and
Europe in discussions about designing a patent system that appropriately rewards
innovation.
As a company that sells billions of dollars a year of products that implement
families of standards such as Ethernet (IEEE 802.3) and WiFi (IEEE 802.11), we
are strong advocates of transparency and predictability relative to licensing terms
for standards-essential patents. We have engaged with the U.S. Department of
Justice’s Antitrust Division (“DOJ”), the Federal Trade Commission (“FTC”), and
DG Competition regarding the question of when, if ever, injunctive relief should be
available to the owner of a standards-essential patent that is subject to a reasonable
and non-discriminatory (“RAND”) or in EU parlance fair, reasonable and nondiscriminatory (“FRAND”) licensing commitment.
Interview conducted by Abigail Slater,
Attorney Advisor, U.S. FTC.
Important as the issue of injunctive relief is, however, it is one example of the
broader problem of a standards development system where the intellectual property
rights policies of leading standards development organizations do not do enough
Concurrences N° 2-2013 I Interview
1
Gil Ohana: Life at the IP/Antitrust intersection
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@ Interview
Going back to my earlier point regarding procedural
convergence, Cisco-Tandberg was a transaction where the
US second-phase clock and the EU first-phase clock ran
together. I should admit that was not our plan. It turned
out that way because of the time we needed to respond
to pre-notification questionnaires we received from DG
Competition. The result was that we found ourselves in the
position of achieving substantial compliance with the second
request issued by the Antitrust Division at around the same
time that we were coming to the end of the first phase in
Europe. That permitted us to negotiate a first phase remedy
with DG Competition at around the time that the Antitrust
Division was concluding its review, leading to the happy
result that the two agencies approved the deal on the same
day.
“[W]e welcome the trend toward
substantive convergence in US and
EU merger enforcement”
With respect to merger enforcement, we welcome the trend
toward substantive convergence in US and EU merger
enforcement, and the increasing trend toward information
sharing between agencies during merger investigations.
When we have transactions that are subject to review by
multiple jurisdictions, we believe the process works best when
different investigating staffs are working from a common set
of facts, subject of course to the possibility that the same
transaction will raise different issues in different places
and to concerns regarding the protection of confidential
information by each of the reviewing agencies. We have
practiced this principle in two recent transactions that
were subject to review in the United States and the EU, our
acquisition of Tandberg in 2009-2010 and our acquisition of
NDS in 2012.
Thanks in part to arguments made by a competitor
complainant, the investigating staffs in both the EU
and the US were focused on interoperability issues, in
particular the (fanciful) concern that Cisco would take steps
after the merger closed to degrade the standards-based
interoperability that had been a hallmark of the Tandberg
videoconferencing products. Since a key reason why we
wanted to acquire Tandberg was to address more quickly
customer concerns with the lack of interoperability in some of
Cisco’s videoconferencing products, committing to preserve
and promote interoperability with the Cisco products by
continuing to license the Telepresence Interoperability
Protocol was an easy decision for Cisco to take.
While there is still ground to cover relative to substantive
convergence, the next frontier in merger enforcement is
procedural convergence. Agency timelines differ, in particular
with respect to how long it takes to get the formal review
process started by having a merger notification accepted.
In Europe, the delay in accepting notifications is driven by
the strict phase one deadlines in the EC Merger Regulation
and the need to assemble facts for use in agency opinions
that explain the agency’s decision to approve or prohibit a
particular transaction. The result for deals that require EU
and US notifications is that unless the merging parties are
willing to delay their US notifications, sometimes for several
months, the agency review clocks will necessarily be out of
alignment.
Of course, working through the details of any proposed
merger remedy is challenging both for the merging parties
and the agencies, particularly when interested third parties
are trying to influence what winds up in the resulting
commitments. DG Competition operates within strict time
limits regarding the negotiation of first-phase remedies.
That made for an exciting, sometimes terrifying, few weeks
as we negotiated draft commitments. Given the nine-hour
time difference between California and Brussels, there were
quite a few early morning and weekend conference calls with
the case team at DG Competition.
Relative to the question of the value of interoperability
remedies in tech merger cases more generally, I think they can
be an important tool for agencies to use in appropriate merger
cases, particularly cases that raise serious vertical concerns.
Cisco is currently appealing the European Commission’s
decision to approve Microsoft’s 2010 acquisition of Skype.
Since the merger, Microsoft has been promoting its Lync
enterprise unified communications product as the only way
for businesses to access the very large Skype and Windows
Live Messenger installed base. We advocated unsuccessfully
for the European Commission to approve Microsoft’s
acquisition of Skype subject to interoperability remedies
similar to those we had agreed to in Cisco-Tandberg and that
Intel had agreed to a few months earlier to end the European
Commission’s investigation of its acquisition of McAfee.
Holding with mergers, in particular the Cisco/Tandberg
merger you mentioned. In March 2010, the DOJ closed
its investigation into Cisco/Tandberg without conditions,
and the EU announced that it had accepted behavioral
commitments to enhance interoperability between its
multi-screen video conferencing products and competitive
products. The DOJ cited the EU commitments in its press
release closing its investigation. This seemed to be a great
result for Cisco. Is there advice you can share about how
that process played out that might be generally applicable
to other merger reviews? In particular, do you see a role
for interoperability commitments in future merger reviews,
and why?
1
Kai Uwe Kühn, Fiona Scott-Morton, and Howard Shelanski, Standard
Setting Organizations Can Help Solve the Standards Essential Patent
Licensing Problem, COMPETITION POLICY INT’L ANTITRUST
CHRONICLE (March 2013) (“In the view of all three of us, many
existing SSOIPR policies are not strong or clear enough to [discourage
hold-up].”).
2
to prevent opportunistic behavior in standards development.
We were encouraged to see that view is shared by prominent
economists that are currently or were recently associated
with the Division, FTC, and DG Competition.1
Cisco both contributes inventions for use in standards
development and implements standards. Standards are
the technological foundation upon which we innovate.
Our success as a vendor of robust, fully featured, and highly
differentiated products speaks to how much innovation we
do on top of standards that we help create.
Fortunately, antitrust enforcement agencies in the United
States, Europe, and elsewhere are increasingly alert to the
impact that opportunistic behavior in the assertion of
standards essential patents can have on consumers. Cisco and
other companies have engaged with antitrust enforcement
agencies to explain our concerns in this area, and are happy
that the agencies share Cisco’s concern with the risk of holdup in the implementation of standards. We have welcomed
the participation of the Antitrust Division, Federal Trade
Commission, and DG Competition at meetings of ETSI and
other standards bodies.
Participation in standards development and the decision to
contribute intellectual property to standards development
efforts is a bargain. Contributors with licensing models
participate because of the lucrative licensing opportunities
that can come from owning patented technology that is
essential to implement a successful standard. But access to
those opportunities comes at a cost, specifically the patentee’s
surrender of some of the rights that a patentee otherwise
reserves, including the unfettered right to exclude.
To give effect to that bargain, commitments to license on
RAND and FRAND terms should be meaningful. It makes no
sense for companies like Cisco to support the work of dozens
of engineers who are engaged in standards development on a
daily basis if any of the dozens or hundreds of participants
in standards development that may own essential patents
could prevent implementation of a standard at any time for
any reason. So I share the view expressed by Judge Posner
and academic commentators that the RAND commitment
should be understood, at a minimum, as surrendering the
unfettered right to enjoin.
What do you see as the most needed reforms of Standard
Setting Organization (“SSO”) policies, from an antitrust
compliance perspective?
There a few key issues that SSOs have been discussing. First,
there needs to be greater clarity regarding when injunctive
relief is appropriate, and, in particular, on the prohibition
on seeking injunctive relief until the accused infringer has
had the opportunity to litigate or arbitrate the value of the
asserted patents as well as defenses such as invalidity and
non-infringement. It would also be beneficial to have greater
clarity regarding the meaning of the “R” element in RAND
or FRAND, in particular to align it with the principles of
inventive contribution that are emerging in recent statements
by the FTC and recent damages opinions from the US
Court of Appeals for the Federal Circuit. There needs to be
an understanding that the obligation to license standards
essential patents means an obligation to license the licensee
that makes the smallest salable patent-practicing product (for
example, a baseband processor in a smartphone), and that the
price of that product, not the much more expensive products
into which it may be inserted, should be the royalty base used
for calculation of a reasonable royalty. Finally, it is important
to recognize that licensing commitments follow standards
essential patents as encumbrances. This point should be clear
in the wake of the FTC’s Negotiated Data Solutions case and
the EU’s similar decision in IPCom.2 Nevertheless, the issue
continues to come up in litigation, sometimes with surprising
results, for example the Vizio v. Funai decision.3
Beyond the question of when, if ever, injunctive relief is
appropriate, there is also the question of what RAND
means. Companies with licensing models have used the fear
of antitrust liability to chill discussion within standards
development organizations of what the “R” component
of RAND and FRAND should mean. This exposes
implementers of standards to royalty stacking, particularly
for products that, as many contemporary multi-function
technology products do, require the implementation of
dozens or hundreds of standards, each of which may require
licenses to dozens, hundreds, or thousands of patents.
As with many costs imposed on an entire industry, the
ultimate victims of opportunistic behavior in standards
development are final consumers, who pay more than they
otherwise would for common technology products such as
smartphones and wireless access points because the cost of
those products include super-competitive patent royalties.
3
2
http://www.ftc.gov/os/caselist/0510094/index.shtm (last visited Mar. 1, 2013); http://
europa.eu/rapid/press-release_MEMO-09-549_en.htm (last visited Mar. 1, 2013).
3
Vizio, Inc. v. Funai Electric Co., Ltd., No. 09-0174 AHM (RCx) (C.D.
Cal. Feb. 3, 2010).
“Our success as a vendor of
robust, fully featured, and highly
differentiated products speaks
to how much innovation we do
on top of standards that we help
create”
Shifting gears to your IP portfolio, would you describe
Cisco’s position on the standard setting process in broad
stroke to us? What general principles apply? How have
these principles informed the company’s position on issues
at the intersection of intellectual property, antitrust law,
and competition policy, such as patent hold-up?
preserves the ability of the implementer to challenge patent
validity, essentiality, and infringement without thereby
subjecting itself to an injunction. One of the things we
have learned from the global smartphone wars is that when
accused infringers have put in the time and effort to challenge
the validity of patents asserted to be essential to implement
standards, courts have determined quite a number of asserted
patents to be invalid. So the FTC was right not to require
parties accused of infringing standards essential patents to
give up validity and other challenges to avoid the threat of
an injunction. That result is consistent with the teaching of
the Supreme Court in Lear v. Adkins: there is an “important
public interest in permitting full and free competition in the
use of ideas which are in reality a part of the public domain.”4
Sorry to duck a “yes” or “no” question, but the question
merits a nuanced response. The lenient antitrust treatment
that standard setting has enjoyed for at least the last two
decades originates in the wise recognition by antitrust
enforcers and courts that standards development is generally
pro-competitive. Standards development is pro-competitive
because it allows implementers of standards to realize
economies of scale, lowers entry barriers, and makes it easier
for purchasers of standards compliant products to switch,
whether by replacing one standards-compliant product with
another, or by adding incrementally to the set of standards
compliant products they own a product made by a different
vendor, secure in the knowledge that the new product will
work with the products they already have.
Some observers have suggested that the competition
agencies have been giving undue attention to abusive
enforcement of SEPs and correspondingly insufficient
attention to abusive enforcement of non-SEP but
“commercially essential” patents. Where do you stand on
this front?
“In the United States, we
are seeing the emergence of
the “direct to consumer” model
of patent assertion”
It is helpful first to specify what is meant by “commercially
essential” patents. If what is meant is patents that are not
essential to implement a standard, but are so broad that any
device will infringe, I am not sure that antitrust enforcement
has much of a role to play. Maybe the patent should not have
been granted in the first place, but that is in the first instance
an issue of patent invalidity, and maybe a symptom of a
patent system in which patents have been granted to freely in
the high tech space.
Of course, if the process of developing standards is not yielding
reliably pro-competitive results, because implementers of
standards are being subjected to opportunistic behavior that
leads, as described above, to higher costs for final consumers,
then it follows that the case for lenient antitrust treatment of
standards development is weakened. That is particularly true
when standards development organizations, though aware (as
they must be) of the risks of opportunistic behavior, do nothing
to prevent it, perhaps because the loudest voices in those
organizations are the participants that have the most to lose
from clarifications to existing IPR policies that would reduce
the risk that implementers would be subjected to hold-up.
If the term “commercially essential” patent means a patent
that is subject to a licensing commitment given outside the
context of standard-setting, for example in a voluntary
licensing commitment that a dominant company gave to
avoid antitrust enforcement, then if implementers of the
patented technology relied on the commitment to license,
refusing to license could raise antitrust concerns as well as
promissory estoppel claims.
What are the most important things that FTC, DOJ, EU and/
or the US PTO should do to address abusive practices by
Patent Assertion Entities (“PAE” or patent trolls)?
What is your cut on the positions the FTC has staked
out, in Robert Bosch and in Google/Motorola, on seeking
injunctive relief for infringements of SEPs subject to FRAND
commitments? Do you agree or disagree with the various
“exceptions” to the prohibition, e.g. when the infringer is
seeking injunctive relief regarding its own SEPs?
In the United States, we are seeing the emergence of the
“direct to consumer” model of PAE assertion. PAEs acquire
patents, then send letters to hundreds or thousands of small
businesses threatening litigation if the consumers do not pay
royalties. The FTC in particular has a role to play through
its consumer protection mission in making sure that the
“invitations to license” that PAEs send to small businesses
are not deceptive. We are also seeing the emergence of the
“captive” PAE, a model in which an operating company
or a group of operating companies fund the acquisition
of patents, which are owned by an independent company.
The company that owns the patents grants licenses to the
operating companies that funded its creation. The funding
companies may be repaid by receiving a share of royalties that
the PAE obtains through its assertion of the acquired patents.
Without getting into a detailed analysis of the two consent
decrees, I think there is a lot of merit to the FTC’s approach,
which, broadly speaking, prohibits injunctive relief until
there has been at least the opportunity for an objective
third-party determination (by a judge or by one or more
arbitrators chosen by the parties) of whether offered licensing
terms are or are not compliant with the RAND or FRAND
licensing obligations assumed by the participant in standards
development or its predecessor in interest.
With respect to the (as of this writing, not yet finalized)
Google consent decree, I was particularly happy to see the
provision (in Section II.E.2 of the decree) that specifically
4
4
395 U.S. 653, 670 (1969).
During 2012, the EU (in April) DOJ (in October) and FTC (in
December) all strongly “suggested” in speeches that SSOs
need to strengthen their patent policies to be more effective
in protecting against patent holdup outcomes. Should SSOs
face antitrust liability if they ignore these admonitions?
This model allows the funding operating companies to avoid
the acquired patents becoming subject to cross-licenses that
they may have entered into with their competitors, and creates
incentives for the PAE to pursue the competitors of the
funding parents. Under the right facts, this model may have
interesting implications relative to groups of competitors
banding together to raise rivals’ costs, implications that
should be of interest to antitrust enforcement agencies. Last,
but certainly not least, the agencies have a role to play in
advocating with patent agencies and courts hearing patent
cases to help shape the patent system so as to mitigate the risk
of abusive conduct by PAEs. Two of the things that drive the
liquid market for patents are the expense of litigating patent
cases, which drives up the nuisance value of patent litigation,
and the currently unsettled case law around patent damages,
which encourages the view that every patent purchased is
potentially lucrative.
Dialing down from the patent wars, is there a particular
antitrust primer that you turn to even today? Similarly, are
there non-antitrust books that you have found useful to your
law practice?
For US law, I regularly use the Areeda and Hovenkamp
treatise and the ABA Antitrust Law Developments series.
For EU law, Richard Whish’s single-volume Competition
Law treatise and the Van Bael treatise are both helpful. For
merger notification work, the Global Competition Review
Merger Control annual is very useful.
Antitrust lawyers and economists can learn a lot from
reading business history. Two books I have recently enjoyed
are Titan, Ron Chernow’s biography of John D. Rockefeller,
and Richard White’s Railroaded. The late Thomas McCraw’s
Prophets of Regulation is a great read for anyone interested in
the interplay between antitrust enforcement and regulation.n
5
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Concurrences - Association of Corporate Counsel

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