Blanket Authorities Initiatives

International Law Section Policy

Blanket Authorities Initiatives

Simply stated, "blanket authority" is the process through which an ABA section or division seeks approval from other ABA entities to present its own view, rather than an official ABA position, to a governmental body. In general, this procedure is employed when the subject matter of the position is extremely technical and when a time-sensitive need exists and it is not possible to have either the ABA House of Delegates or ABA Board of Governors go through the regular process for adopting Association policy.

Below is a list of current blanket authority initiatives of the Section. Please be advised that members must follow the policy procedure and usage guidelines outlined in the American Bar Association's Constitution and Bylaws, Rules of Procedure of the House of Delegates. The handbook on blanket authority can be found here:
Blanket Authority Handbook 2011-2012.

Comments of the Antitrust and International Law Sections on the Mexican Competition commission's request for comments on the proposed regulatory provisions implementing the Mexican Federal Competition Law
Comments

Joint Comments by the International Law, Antitrust, and IP Sections on the Public Comment Draft of China's Supreme People's Court's Decision on Revising Application of the Law in the Hearing of Patent Dispute Cases.
Comments

Joint comments by the Sections of International Law and Individual Rights and Responsibilities to the Law Commission of India, regarding its Consultation Paper on India's Media Law.
Cover Letter | Comments

Joint comments of the Antitrust and International Law Sections on Attourney-Client Privilege in response to the public consultation issued by the Cabinet Office of the Government of Japan.
Cover Letter | Comments

Joint comments by the Antitrust, IP and International Law Sections on SAIC's Draft IP Abuse Rules.
Cover Letter | Comments

Joint Comments with the Section of Intellectual Property Law on amendments to the Canadian Trade-marks Act.
Cover Letter | Comments

Joint comments with the Section of Antitrust Law to the Irish Competition Authority regarding its public consultation on the Draft Merger Guidelines.
Cover Letter | Comments

Joint comments with the Section of Antitrust Law on the European Commission regarding HT. 3053: Possible Improvements to the EU Merger Regulation.
Cover Letter | Comments

Joint comments with the Section of Antitrust Law to the United Kingdom’s Department for Business Innovation & Skills in response to its open consultation inviting comment on draft guidance for the new Competition and Markets Authority.
Cover Letter | Comments

Joint comments with the Section of Antitrust Law to the Australian Competition and Consumer Commission regarding the draft Merger Review Process Guidelines.
Cover Letter | Comments

Joint comments with the Section of Antitrust Law on the COMESA Draft Guidelines on Public Interest and Application of Articles 16 and 19 (Horizontal and Vertical Business Practices) and 18 (Abuse of Dominance).
Cover Letter | Comments

Joint comments with the Section of Antitrust Law to Spain’s Comisión Nacional de Competencia (“CNC”) regarding its draft Notice on Leniency.
Cover Letter | Comments

Joint comments with the Section of Antitrust Law in response to the COMESA Competition Commission’s request for comments on the Proposed Draft Guidelines to the COMESA Competition Regulations, 2004.
Cover Letter | Comments

Joint comments with the Section of Antitrust Law on the “Strategy Document” of the Netherlands Authority for Consumers and Markets.
Cover Letter | Comments

Joint comments from the Sections of Antitrust Law and International Law to China’s Ministry of Commerce concerning its Comment Draft of the Interim Regulation on Standards Applicable to Simple Cases of Concentrations of Business Operators.
Cover Letter | Comments

Joint comments of the Section of Antitrust Law, the Section of Intellectual Property Law, the Section of International Law, and the Section of Science & Technology Law on the European Commission’s public consultation regarding its draft proposal for a revised block exemption for technology transfer agreements (“Draft TTBER”) and for revised guidelines (“Draft Guidelines”).
Comments

Joint Comments of the ABA Section of Intellectual Property Law and Section of International Law on the Draft Regulatory Measures on National Standards Involving Patents (interim) for the People’s Republic of China
English | Chinese

Joint comments with the Section of Antitrust Law on the United Kingdom’s Competition Commission’s Draft "Guidelines for Market Investigations" for Public Consultation.
Cover Letter | Comments

Joint comments of the ABA Sections of Antitrust Law, Intellectual Property Law, and International Law regarding China's State Administration for Industry and Commerce (SAIC) Guide on Anti-Monopoly Law Enforcement in the Field of Intellectual Property Rights
Cover Letter | Comments

Joint comments of the ABA Section of Intellectual Property Law and Section of International Law on the Draft Investors' Remuneration Regulations for the People's Republic of China
English | Chinese

Joint comments of the Sections of Antitrust Law and International Law on the proposed regulation of the European Parliament and of the European Council on the Protection of Individuals with Regard to the Processing of Personal Data and on the Free Movement of Such Data.
Comments

Joint comments of the Sections of Antitrust Law and International Law to the Proposal for a Regulation of the European Parliament and of the Council on the Protection of Individuals with regard to the Processing of Personal Data and on the Free Movement of Such Data.
Cover Letter | Comments

Joint comments on the Draft Amendments to the People's Republic of China Patent Law.
Comments

Joint comments on the Colombian Superintendent's Draft Guidelines on Trade Associations.
Cover Letter | Comments

Joint comments on the United Kingdom’s Office of Fair Trading consultation paper entitled Review of the OFT’s Investigation Procedures in Competition Cases.
Cover Letter | Comments

Joint comments on the draft amendments of the Copyright Law of the People’s Republic of China.
Cover Letter | Comments

Joint comments in response to the Canadian Competition Bureau’s request for comments regarding its Draft Updated Enforcement Guidelines on the Abuse of Dominance Provisions.
Cover Letter | Comments

Joint comments in response to Brazil’s Administrative Council for Economic Defense (CADE) Proposed Regulations on Merger Control and on Calculation of Fines in Cartel Cases.
Cover Letter | Comments - English | Comments - Portugese

Joint comments in response to the European Commission’s request for comments on its Green Paper – Towards an integrated European market for card, internet and mobile payments.
Cover Letter | Comments

Joint comment in response to the European Commission's request for comments on its Treaty on Categories of Technology Transfer Agreements and the Commission Notice on Guidelines on the Application to Technology Transfer Agreements.
Cover Letter | Comments

Joint comment in response to the United Kingdom Office of Fair Trading (OFT) regarding its draft detailed guidance on the principles and processes for applications for leniency and no-action in cartel cases.
Cover Letter | Comments

Joint comment in response to the United Kingdom Office of Fair Trading (OFT) regarding its draft revised guidance as to the appropriate amount of penalty.
Cover Letter | Comments

Comments to the European Commission on the European Approach in Collective Redress
Cover Letter | Comments

Joint comments to the PRC Proposed Trademark Law.
Cover Letter | Comments

Joint comment in response to the European Commission's request for comments on its Draft Guidance Paper on quantifying harm in antitrust damages actions.
Cover Letter | Comments

Joint comments to the Bundeskartellamt on its draft Guidance on Substantive Merger Control.
Cover Letter | Comments

Comments on the US Department of Commerce Bureau of Industry and Security's revisions to the Export Administration Regulations.
Comments

Joint comments on the Canadian Competition Bureau's Merger Enforcement Guidelines
Cover Letter | Comments

Joint comments United Kingdom's Department of Business Innovation & Skills "A Competition Regime for Growth: A Consultation on Options for Reform."
Cover Letter | Comments

Comments to the U.S. Department of Commerce, International Trade Administration, Foreign-Trade Zone Board regarding proposed revisions to the Regulations of the Foreign-Trade Zone Board.
Comments

Comments on the proposed rule issued by the U.S. Department of State's Directorate of Defense Trade (DDTC) concerning proposed amendments to the definition of "defense service" under the International Traffic in Arms Regulations (ITAR).
Comments

Joint comments on the Provision on Relevant Issues Concerning the Applications of Law in the Trial of Civil Monopoly Dispute Cases of China's Supreme People's Court.
Cover Letter | Comments

Joint comments regarding the European Commission Staff's Working Document on Collective Redress.
Cover Letter | Comments

Joint comments regarding the Chinese Ministry of Industry and Information Technology's Draft Interim Measures for Supervision and Management of the Internet Information Service Market.
Cover Letter | Comments

Joint comments to the French Competition Commission regarding its Draft Notice on Fines.
Cover Letter | Comments

Joint comments on the draft Competition Commission of India (Procedure in Regard to the Transaction of Business Relating to Combination) Regulations.
Cover Letter | Comments

Joint comments regarding the USTR's Anti-Counterfeiting Trade Agreement.
Cover Letter | Comments

Joint comments regarding the Competition Bureau of Canada's Discussion Paper for the Merger Enforcement Guidelines.
Cover Letter | Comments

Joint comments regarding the United Kingdom Office of Fair Trading (OFT) consultation paper entitled A guide to the OFT's Competition Act of 1998 investigation procedures.
Cover Letter | Comments

Joint comments on proposed amendments to the Hart Scott-Rodino Premerger Notification Rules, the Premerger Notification and Report Form, and associated instructions.

Joint comments regarding the Irish Competition Authority's proposed revisions to the Cartel Immunity Programme.
Cover Letter | Comments

Joint comments to the U.S. Department of State, Directorate of Defense Trade Controls on proposed ITAR changes.

Joint comments to the State Administration of Industry and Commerce and the Legislative Affairs Office of the State Council for consideration by the Chinese Trademark Office.
Cover Letter | Comments

Joint comments on China's State Administration for Industry and Commerce Draft Regulations on the Prohibition of Acts of Monopoly Agreements, of Abuse of Dominant Market Position and of Abuse of Administrative Powers.
Cover Letter | Comments

Joint comments to the European Commission regarding its Draft Regulations and Guidelines for the Assessment of Cooperation Agreements Between Competitors.
Cover Letter | Comments

Joint comments to the Competition Commission and Office of Fair Trading at the U.S. Department of Treasury regarding their joint Draft Merger Assessment Guidelines.
Cover Letter | Comments

Joint comments to the United Nations Commission on International Trade Law on UNCITRAL draft revised Arbitration Rules.

Comments to the Office of Foreign Assets Control at the U.S. Department of Treasury regarding the Economic Sanctions Enforcement Guidelines.

Joint comments in response to the request for comments issued by the European Commission regarding the Consultation Documents on Improved Transparency and Predictability in Competition Proceedings.
Cover Letter | Comments

Joint comments to the New Zealand Commerce Commission regarding its Draft Mergers and Acquisitions Divestment Remedies Guidelines.
Cover Letter | Comments

Joint comments to the Secretariat of Economic Law of Brazil's Ministry of Justice on the Secretaria de Direito Econômico do Ministério da Justiça (SDE) Guidelines.
Cover Letter | Comments

Comments regarding the Anti-Pricing Monopoly Regulation (Comment Draft) (“Draft Anti-Pricing Monopoly Regulation” or “Draft Regulation”) of China's National Development & Reform Commission (“NDRC”) published for comment on August 12, 2009.

Joint comments to the European Commission on its Proposal for Revised Block Exemption Regulation and Guidelines on Vertical Restraints.
Cover Letter | Comments

Joint comments on the Japan Fair Trade Commission's Draft Guidelines for the Exclusionary Private Monopolization under the Antimonopoly Act.
Cover Letter | Comments

Joint comments to the Competition Bureau of Canada regarding its public consultation draft Competitor Collaboration Guidelines.
Cover Letter | Comments

Joint comments to the United Kingdom Competition Commission and Office of Fair Trading regarding Draft Merger Assessment Guidelines.
Cover Letter | Comments

Joint comments on the SAIC Draft Regulations on the Prohibition of Acts of Monopoly Agreements and of Abuse of Dominant Market Position.
Cover Letter | Comments

Joint comments on the Revised Draft Information Bulletin on Sentencing and Leniency in Cartel Cases issued by the Competition Bureau of Canada.
Cover Letter | Comments

Joint comments to the Competition Bureau of Canada regarding its Draft Enforcement Guidelines on the Revised Merger Review Process.
Cover Letter | Comments

Canadian Competition Bureau on its Draft Updated Enforcement Guidelines on the Abuse of Dominance Provisions.
Cover Letter | Comments

Joint comments on the aspects of the Guidelines for Definition of Relevant Market of China's Ministry of Commerce.
Cover Letter | Comments

Joints Comments in response to the questionnaire issued by the European Commission in Connection with its Review of the Current Regime for the Assessment of Horizontal Cooperation Agreements.
Cover Letter | Comments

Joint Comments on Paraguay's “In Defense of Competition Bill.”
Cover Letter | Comments

Joint Comments four Provisional Measures relating to the treatment of concentrations between undertakings under the Anti-Monopoly Law.
Cover Letter | Comments

Joint comments in response to the questionnaire issued by the European Commission in conjunction with its report on regulation 139/2004 (Merger Regulation).

Joint Comments on Draft Amendments to Patent Law of the People's Republic of China.
Cover Letter | Comments

Comments on certain expansions of the jurisdiction of the U.S. Court of International Trade as set out in the proposed Court of International Trade Improvement Act of 2008.

Joint comments on the Australian Commonwealth Treasury's Discussion Paper on Creeping Acquisitions
Cover Letter | Comments

Joint comments regarding the Israel Antitrust Authority's proposed Amendment to the Restrictive Trade Practices Law, 5748-1988 for the purpose of Regulating Oligopolies
Cover Letter | Comments

Joint Comments to the European Commission Regarding its Draft Notice on Remedies Acceptable under Council Regulation (EEC) No 139/2004 and under Commission Regulation (EC) No 802/2004.
Cover Letter | Comments

Joint Comments Regarding the Draft Guidelines on the Assessment of Non- horizontal Mergers Under the Council Regulation on the Control of Concentrations Between Undertakings.
Cover Letter | Comments

Comments on Canadian Competition Bureau's Request for Public Comments on the Draft Information Bulletin on the Abuse of Dominance Provisions as Applied to the Telecommunications Industry.

Comments to the United States Department of Commerce, Bureau of Industry and Security regarding the proposed regulation “Revision and Clarification of Export and Reexport Controls for the Peoples' Republic of China: New Authorization Validated End-User.” – sent 12/14/06, valid through 3/14/07

Joint comments on draft amendments (Draft Amendments) to the Patent Law of the People's Republic of China (PRC), published for comments on July 31, 2006 by the PRC State Intellectual Property Office (SIPO). – sent 9/12/06, valid through 12/12/06

Comments to the U.S. Department of State regarding the United Nations Convention on the Use of Electronic Communications in International Contracts – sent 6/8/06, valid through 6/7/08

Comments to the Commission of the European Communities on the Commission's Discussion Paper on the Application of Article 82 of the Treaty to Exclusionary Abuses – sent 6/5/06, valid through 6/4/08

Comments to the Commission of the European Communities on damage action for breaches of EU antitrust rules – sent 5/1/06, valid through 4/30/08

Comments to the Antitrust Modernization Commission regarding the role of comity in international competition law enforcement – sent 3/29/06, valid through 6/27/06

Joint Comments on the Competition Bureau (Canada) Information Bulletin on the Communication and Treatment of Information under the Competition Act – sent 3/29/06, valid through 6/27/06

Comments to the Securities and Exchange Commission Release No. 34-5020, International Series Release No. 1295 Termination of a Foreign Private Issuer's Registration of a Class of Securities Under Section 12(g) and Duty to File Reports Under Section 15(d) of the Securities Exchange Act of 1934 – sent 3/17/06, valid through 3/16/08

Joint comments on the Competition Bureau Draft Information Bulletin on Merger Remedies in Canada – sent 3/1/06, valid through 5/29/06

Joint comments to the Antitrust Modernization Commission regarding international topics and immunities and exemption – sent 9/1/05, valid through 8/30/07

Joint Comments to the Commonwealth of Australia regarding the draft legislation providing criminal penalties for serious cartel conduct.
Cover Letter | Comments

Joint Comments to the Japan Fair Trade Commission regarding its Proposed Amendments to the Japan Antimonopoly Law.
Cover Letter | Comments

Joint Comments to the Legislative Affairs Office of the State Council regarding the Draft for Comments of the State Council Regulations on Notifications of Concentrations of Undertakings.
Cover Letter | Comments

Joint Comments on Proposed Draft of the Competition Commission of India (General) Regulations, Draft Competition Commission (Lesser Penalty) Regulations, and Draft Competition Commission (Determination of Cost of Production) Regulations.

Comments to the Commission of the European Communities regarding its White Paper on damages actions for breach of the EC antitrust rules and the accompanying Commission Staff Working Paper and Commission Staff Impact Assessment Report
Cover Letter | Comments

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