Privacy Comments of the International Center for Law & Economics, Restoring Internet Freedom NPRM, FCC

Policy Comments, Restoring Internet Freedom NPRM

"Federal administrative agencies are required to engage in “reasoned decisionmaking” based on a thorough review and accurate characterization of the record. Their analysis must be based on facts and reasoned predictions; it must be rooted in sound economic reasoning: it must be logically coherent..."

Regulatory Comments

Comments, California DMC Autonomous Vehicle Rules, California DMV

"On behalf of the R Street Institute, the Competitive Enterprise Institute, TechFreedom, and the International Center for Law & Economics, we respectfully submit these comments in response to the California Department of Motor Vehicles’ proposed Driverless Testing and Deployment Regulations released on March 10, 2017..."

Regulatory Comments

Comments, In the Matter of Certain Carbon and Steel Alloy Products, ITC

"A cornerstone of the Initial Determination is that “[u]nder TianRui, the Commission’s discretion cannot be exercised in a way that conflicts with applicable federal law,”1 and, therefore, that “the dispute between U.S. Steel and Respondents in this case must be resolved using the same substantive law that governs federal antitrust cases.”

Regulatory Comments

Policy Response, First Proposal on Copyright Reform

"Given the importance of copyright protection to the US national interest, including from an economic, political and social perspective (on which, please see our response to the Register’s request for comments, attached), we strongly agree with the proposal set forth by the Committee to reform the Copyright Office..."

Written Testimonies & Filings

Amicus Brief, LabMD Inc., v. FTC, 11th Circuit

Section 5 of the Federal Trade Commission Act, 15 U.S.C. § 45 [“Section 5”], is a consumer protection statute, not a data security rule...This fundamental point has been lost in the Commission’s approach to data security.

Amicus Brief