Intellectual Property Rights in IETF Technology
RFC 8179 also known as BCP 79

Internet Engineering Task Force (IETF) S. Bradner
Request for Comments: 8179 Harvard University
BCP: 79 J. Contreras
Obsoletes: 3979, 4879 University of Utah
Updates: 2026 May 2017
Category: Best Current Practice
ISSN: 2070-1721
 Intellectual Property Rights in IETF Technology
Abstract
 The IETF policies about Intellectual Property Rights (IPR), such as
 patent rights, relative to technologies developed in the IETF are
 designed to ensure that IETF working groups and participants have as
 much information as possible about any IPR constraints on a technical
 proposal as early as possible in the development process. The
 policies are intended to benefit the Internet community and the
 public at large, while respecting the legitimate rights of IPR
 holders. This document sets out the IETF policies concerning IPR
 related to technology worked on within the IETF. It also describes
 the objectives that the policies are designed to meet. This document
 updates RFC 2026 and, with RFC 5378, replaces Section 10 of RFC 2026.
 This document also obsoletes RFCs 3979 and 4879.
Status of This Memo
 This memo documents an Internet Best Current Practice.
 This document is a product of the Internet Engineering Task Force
 (IETF). It represents the consensus of the IETF community. It has
 received public review and has been approved for publication by the
 Internet Engineering Steering Group (IESG). Further information on
 BCPs is available in Section 2 of RFC 7841.
 Information about the current status of this document, any errata,
 and how to provide feedback on it may be obtained at
 http://www.rfc-editor.org/info/rfc8179.
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Copyright Notice
 Copyright (c) 2017 IETF Trust and the persons identified as the
 document authors. All rights reserved.
 This document is subject to BCP 78 and the IETF Trust's Legal
 Provisions Relating to IETF Documents
 (http://trustee.ietf.org/license-info) in effect on the date of
 publication of this document. Please review these documents
 carefully, as they describe your rights and restrictions with respect
 to this document. Code Components extracted from this document must
 include Simplified BSD License text as described in Section 4.e of
 the Trust Legal Provisions and are provided without warranty as
 described in the Simplified BSD License.
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Table of Contents
 1. Definitions . . . . . . . . . . . . . . . . . . . . . . . . . 4
 2. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . 6
 3. Participation in the IETF . . . . . . . . . . . . . . . . . . 8
 3.1. General Policy . . . . . . . . . . . . . . . . . . . . . . 8
 3.2. Rights and Permissions in Contributions. . . . . . . . . . . 8
 3.3. Obligations on Participants . . . . . . . . . . . . . . . . 8
 4. Actions for Documents for Which IPR Disclosure(s)
 Have Been Received . . . . . . . . . . . . . . . . . . . . . 8
 5. IPR Disclosures . . . . . . . . . . . . . . . . . . . . . . . 10
 5.1. Who Must Make an IPR Disclosure? . . . . . . . . . . . . . . 10
 5.1.1. A Contributor's IPR in His or Her Contribution . . . . . 10
 5.1.2. An IETF Participant's IPR in Contributions by Others . . 10
 5.1.3. IPR of Others . . . . . . . . . . . . . . . . . . . . . . 10
 5.2. The Timing of Providing Disclosure . . . . . . . . . . . . . 11
 5.2.1. Timing of Disclosure under Section 5.1.1 . . . . . . . . . 11
 5.2.2. Timing of Disclosure under Section 5.1.2 . . . . . . . . . 11
 5.2.3. Timing of Disclosure by ADs and Others . . . . . . . . . . 12
 5.3. How Must an IPR Disclosure be Made? . . . . . . . . . . . . 12
 5.4. What Must be in an IPR Disclosure? . . . . . . . . . . . . . 12
 5.4.1. Content of IPR Disclosures . . . . . . . . . . . . . . . . 12
 5.4.2. Updating IPR Disclosures . . . . . . . . . . . . . . . . . 12
 5.4.3. Blanket IPR Statements . . . . . . . . . . . . . . . . . . 13
 5.5. Licensing Information in an IPR Disclosure . . . . . . . . . 14
 5.6. Level of Control over IPR Requiring Disclosure . . . . . . . 15
 5.7. Disclosures for Oral Contributions . . . . . . . . . . . . . 15
 5.8. General Disclosures . . . . . . . . . . . . . . . . . . . . 15
 6. Failure to Disclose . . . . . . . . . . . . . . . . . . . . . 16
 7. Evaluating Alternative Technologies in IETF Working Groups . . 17
 8. Change Control for Technologies . . . . . . . . . . . . . . . 19
 9. Licensing Requirements to Advance Standards Track
 IETF Documents . . . . . . . . . . . . . . . . . . . . . . . . 19
 10. No IPR Disclosures in IETF Documents . . . . . . . . . . . . 19
 11. Application to Non-IETF Stream Documents . . . . . . . . . . 19
 12. Security Considerations . . . . . . . . . . . . . . . . . . 20
 13. Changes since RFCs 3979 and 4879 . . . . . . . . . . . . . . 20
 14. References . . . . . . . . . . . . . . . . . . . . . . . . . 25
 14.1. Normative References . . . . . . . . . . . . . . . . . . . 25
 14.2. Informative References . . . . . . . . . . . . . . . . . . 26
 Editors' Addresses . . . . . . . . . . . . . . . . . . . . . . . 26
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1. Definitions
 The following definitions are for terms used in the context of this
 document. Other terms, including "IESG," "ISOC," "IAB," and "RFC
 Editor," are defined in [RFC2028].
 a. "Alternate Stream": the IAB Document Stream, the IRTF Document
 Stream, and the Independent Submission Stream, each as defined in
 Section 5.1 of [RFC4844], along with any future non-IETF streams
 that might be defined.
 b. "Blanket IPR Statement" or "Blanket Disclosure": see Section
 5.4.3.
 c. "Contribution": any submission to the IETF intended by the
 Contributor for publication as all or part of an Internet-Draft or
 RFC and any statement made within the context of an IETF activity,
 in each case that is intended to affect the IETF Standards Process
 or that is related to the activity of an Alternate Stream that has
 adopted this policy.
 Such statements include oral statements, as well as written and
 electronic communications, which are addressed to:
 o any IETF plenary session,
 o any IETF working group (WG; see BCP 25) or portion thereof or
 any WG chair on behalf of the relevant WG,
 o any IETF "birds of a feather" (BOF) session or portion thereof,
 o WG design teams (see BCP 25) and other design teams that intend
 to deliver an output to IETF, or portions thereof,
 o the IESG, or any member thereof on behalf of the IESG,
 o the IAB, or any member thereof on behalf of the IAB,
 o any IETF mailing list, web site, chat room, or discussion board
 operated by or under the auspices of the IETF, including the
 IETF list itself,
 o the RFC Editor or the Internet-Drafts function.
 Statements made outside of an IETF session, mailing list, or other
 function, or that are clearly not intended to be input to an IETF
 activity, group, or function, are not Contributions in the context
 of this document. And while the IETF's IPR rules apply in all
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 cases, not all presentations represent a Contribution. For
 example, many invited plenary, area-meeting, or research group
 presentations will cover useful background material, such as
 general discussions of existing Internet technology and products,
 and will not be a Contribution. (Some such presentations can
 represent a Contribution as well, of course). Throughout this
 document, the term "written Contribution" is used. For purposes
 of this document, "written" means reduced to a written or visual
 form in any language and any media, permanent or temporary,
 including but not limited to traditional documents, email
 messages, discussion board postings, slide presentations, text
 messages, instant messages, and transcriptions of oral statements.
 d. "Contributor": an individual submitting a Contribution
 e. "Covers" or "Covered": a valid claim of a patent or a patent
 application (including a provisional patent application) in any
 jurisdiction, or any other Intellectual Property Right, would
 necessarily be infringed by the exercise of a right (e.g., making,
 using, selling, importing, distribution, copying, etc.) with
 respect to an Implementing Technology. For purposes of this
 definition, "valid claim" means a claim of any unexpired patent or
 patent application which shall not have been withdrawn, cancelled,
 or disclaimed, nor held invalid by a court of competent
 jurisdiction in an unappealed or unappealable decision.
 f. "General Disclosure": see Section 5.8.
 g. "IETF": In the context of this document, the IETF includes all
 individuals who participate in meetings, working groups, mailing
 lists, functions, and other activities that are organized or
 initiated by ISOC, the IESG, or the IAB under the general
 designation of the Internet Engineering Task Force, or IETF, but
 solely to the extent of such participation.
 h. "IETF Documents": RFCs and Internet-Drafts that are published as
 part of the IETF Standards Process. These are also referred to as
 "IETF Stream Documents" as defined in Section 5.1.1 of [RFC4844].
 i. "IETF Standards Process": the activities undertaken by the IETF in
 any of the settings described in the above definition of
 Contribution. The IETF Standards Process may include
 participation in activities and publication of documents that are
 not directed toward the development of IETF standards or
 specifications, such as the development and publication of
 Informational and Experimental documents (see Section 4 of
 [RFC2026]).
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 j. "IPR" or "Intellectual Property Rights": means a patent, utility
 model, or similar right that may Cover an Implementing Technology,
 whether such rights arise from a registration or renewal thereof,
 or an application therefore, in each case anywhere in the world.
 See [RFC5378] for a discussion of trademarks.
 k. "Implementing Technology": a technology that implements an IETF
 specification or standard.
 l. "Internet-Draft": a document used in the IETF and RFC Editor
 processes, as described in Section 2.2 of [RFC2026].
 m. "Participating in an IETF discussion or activity": making a
 Contribution, as described above, or in any other way acting in
 order to influence the outcome of a discussion relating to the
 IETF Standards Process. Without limiting the generality of the
 foregoing, acting as a Working Group Chair or Area Director
 constitutes "Participating" in all activities of the relevant
 working group(s) he or she is responsible for in an area.
 "Participant" and "IETF Participant" mean any individual
 Participating in an IETF discussion or activity.
 m. "Reasonably and personally known": something an individual knows
 personally or, because of the job the individual holds, would
 reasonably be expected to know. This wording is used to indicate
 that an organization cannot purposely keep an individual in the
 dark about patents or patent applications just to avoid the
 disclosure requirement. But this requirement should not be
 interpreted as requiring the IETF Contributor or Participant (or
 his or her represented organization, if any) to perform a patent
 search to find applicable IPR.
 o. "RFC": the basic publication series for the IETF. RFCs are
 published by the RFC Editor. (See Section 2.1 of [RFC2026].)
2. Introduction
 The IETF policies about Intellectual Property Rights (IPR), such as
 patent rights, relative to technologies developed in the IETF are
 designed to ensure that IETF working groups and Participants have as
 much information as possible about any IPR constraints on a technical
 proposal as early as possible in the development process. The
 policies are intended to benefit the Internet community and the
 public at large, while respecting the legitimate rights of IPR
 holders. This document details the IETF policies concerning IPR
 related to technology worked on within the IETF. It also describes
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 the objectives that the policies are designed to meet. This document
 updates RFC 2026 and, with RFC 5378, replaces Section 10 of RFC 2026.
 This document also obsoletes RFC 3979 and RFC 4879.
 There are three basic principles regarding how the IETF deals with
 claims of Intellectual Property Rights (originally outlined in
 Section 10 of [RFC2026]):
 (a) The IETF will make no determination about the validity of any
 particular IPR claim.
 (b) The IETF, following normal processes, can decide to use
 technology for which IPR disclosures have been made if it decides
 that such a use is warranted.
 (c) In order for a working group and the rest of the IETF to have the
 information needed to make an informed decision about the use of
 a particular technology, all those contributing to the working
 group's discussions must disclose the existence of any IPR the
 Contributor or any other IETF Participant believes Covers or may
 ultimately Cover the technology under discussion. This applies
 to both Contributors and other Participants, and applies whether
 they contribute in person, via email, or by other means. The
 requirement applies to all IPR of the Participant, the
 Participant's employer, sponsor, or others represented by the
 Participant that are reasonably and personally known to the
 Participant. No patent search is required.
 Section 1 defines the terms used in this document. Sections 3
 through 11 set forth the IETF's policies and procedures relating to
 IPR. Section 13 lists the changes between this document and RFCs
 3979 and 4879. A separate document [RFC5378] deals with rights (such
 as copyrights and trademarks) in Contributions, including the right
 of the IETF and IETF Participants to publish and create derivative
 works of those Contributions. This document is not intended to
 address those issues. See RFC 6702 [RFC6702] for a discussion of
 "Promoting Compliance with Intellectual Property Rights (IPR)
 Disclosure Rules".
 This document is not intended as legal advice. Readers are advised
 to consult their own legal advisors if they would like a legal
 interpretation of their rights or the rights of the IETF in any
 Contributions they make.
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3. Participation in the IETF
3.1. General Policy
 In all matters relating to Intellectual Property Rights, the intent
 is to benefit the Internet community and the public at large, while
 respecting the legitimate rights of others. The disclosures required
 by this policy are intended to help IETF working groups define
 superior technical solutions with the benefit of as much information
 as reasonably possible about potential IPR claims relating to
 technologies under consideration.
3.2. Rights and Permissions in Contributions
 By submission of a Contribution, each person actually submitting the
 Contribution, and each named co-Contributor, is deemed to agree to
 the following terms and conditions on his or her own behalf and on
 behalf of the organizations the Contributor represents or is
 sponsored by (if any) when submitting the Contribution.
3.3. Obligations on Participants
 By Participating in the IETF, each Participant is deemed to agree to
 comply with all requirements of this RFC that relate to Participation
 in IETF activities. Without limiting the foregoing, each Participant
 that is a Contributor makes the following representations to the
 IETF:
 A. Such Contributor represents that he or she has made or will
 promptly make all disclosures required by Section 5.1.1 of this
 document.
 B. Such Contributor represents that there are no limits to the
 Contributor's ability to make the grants, acknowledgments, and
 agreements herein that are reasonably and personally known to the
 Contributor.
4. Actions for Documents for Which IPR Disclosure(s) Have Been Received
 A. The IESG, IAB, ISOC, and IETF Trust disclaim any responsibility
 for identifying the existence of or for evaluating the
 applicability of any IPR, disclosed or otherwise, to any IETF
 technology, specification, or standard, and will take no position
 on the validity or scope of any such IPR.
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 B. When the IETF Secretariat has received a notification under
 Section 5.1.3 of the existence of non-participant IPR that
 potentially Covers a technology under discussion at IETF or which
 is the subject of an IETF Document, the IETF Secretariat shall
 promptly publish such notification and will request that the
 identified third party make an IPR disclosure in accordance with
 the provisions of Section 5.
 C. When an IPR disclosure has been made as provided in Section 5 of
 this document, the IETF Secretariat may request from the purported
 holder of such IPR a written assurance that upon approval by the
 IESG for publication of the relevant IETF specification(s) as one
 or more RFCs, all persons will be able to obtain the right to
 implement, use, distribute, and exercise other rights with respect
 to Implementing Technology under one of the licensing options
 specified in Section 5.5.A below unless a statement identifying
 one of the licensing options described in Section 5.5.A has
 already been received by the IETF Secretariat. The working group
 proposing the use of the technology with respect to which the
 Intellectual Property Rights are disclosed may assist the IETF
 Secretariat in this effort.
 The results of this procedure shall not, in themselves, block
 publication of an IETF Document or advancement of an IETF Document
 along the Standards Track. A working group may take into
 consideration the results of this procedure in evaluating the
 technology, and the IESG may defer approval when a delay may
 facilitate obtaining such assurances. The results will, however,
 be recorded by the IETF Secretariat and be made available online.
 D. The IESG will not make any determination that any terms for the
 use of an Implementing Technology (e.g., the assurance of
 reasonable and non-discriminatory terms) have been fulfilled in
 practice. It will instead apply the normal requirements for the
 advancement of Internet Standards (see RFC 6410). If the two
 unrelated implementations of the specification that are required
 to advance from Proposed Standard to Internet Standard have been
 produced by different organizations or individuals, or if the
 "significant implementation and successful operational experience"
 required to advance from Proposed Standard to Internet Standard
 has been achieved, the IESG will presume that the terms are
 reasonable and to some degree non-discriminatory. Note that this
 also applies to the case where multiple implementers have
 concluded that no licensing is required.
 This presumption may be challenged at any time, including during
 the Last Call period by sending email to the IESG.
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5. IPR Disclosures
 This document refers to the IETF Participant making disclosures,
 consistent with the general IETF philosophy that Participants in the
 IETF act as individuals. A Participant's obligation to make a
 disclosure is also considered satisfied if the IPR owner, which may
 be the Participant's employer or sponsor, makes an appropriate
 disclosure in place of the Participant doing so.
5.1. Who Must Make an IPR Disclosure?
5.1.1. A Contributor's IPR in His or Her Contribution
 Any Contributor who reasonably and personally knows of IPR meeting
 the conditions of Section 5.6 which the Contributor believes Covers
 or may ultimately Cover his or her written Contribution that is
 intended to be used as an input into the IETF Standards Process, or
 which the Contributor reasonably and personally knows his or her
 employer or sponsor may assert against Implementing Technologies
 based on such written Contribution, must make a disclosure in
 accordance with Section 5.
5.1.2. An IETF Participant's IPR in Contributions by Others
 If an individual's Participation relates to a written Contribution
 made by somebody else that is intended to be used as an input into
 the IETF Standards Process, and such Participant reasonably and
 personally knows of IPR meeting the conditions of Section 5.6 which
 the Participant believes Covers or may ultimately Cover that
 Contribution, or which the Participant reasonably and personally
 knows his or her employer or sponsor may assert against Implementing
 Technologies based on such written Contribution, then such
 Participant must make a disclosure in accordance with Section 5.
5.1.3. Voluntary IPR Disclosures
 If any person has information about IPR that may Cover a technology
 relevant to the IETF Standards Process, but such person is not
 required to disclose such IPR under Sections 5.1.1 or 5.1.2 above,
 such person is nevertheless encouraged to file an IPR disclosure as
 described in Section 5.3 below. Such an IPR disclosure should be
 filed as soon as reasonably possible after the person realizes that
 such IPR may Cover a Contribution. Situations in which such
 voluntary IPR disclosures may be made include when (a) IPR does not
 meet the criteria in Section 5.6 because it is not owned or
 controlled by an IETF Participant or his or her sponsor or employer
 (referred to as third party IPR), (b) an individual is not required
 to disclose IPR meeting the requirements of Section 5.6 because that
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 individual is not Participating in the relevant IETF activity, or (c)
 the IPR Covers technology that does not yet meet the criteria for a
 Contribution hereunder (e.g., it is disclosed in an informal or other
 non-IETF setting).
5.2. The Timing of Disclosure
 Timely IPR disclosure is important because working groups need to
 have as much information as they can while they are evaluating
 alternative solutions.
5.2.1. Timing of Disclosure under Section 5.1.1
 A. The IPR disclosure required pursuant to Section 5.1.1 must be made
 as soon as reasonably possible after the Contribution is submitted
 or made unless the required disclosure is already on file. See
 Section 5.4.2 for a discussion of when updates need to be made for
 an existing disclosure.
 B. If a Contributor first learns of IPR in its Contribution that
 meets the conditions of Section 5.6, for example a new patent
 application or the discovery of a relevant patent in a patent
 portfolio, after the Contribution is published in an Internet-
 Draft, a disclosure must be made as soon as reasonably possible
 after the IPR becomes reasonably and personally known to the
 Contributor.
5.2.2. Timing of Disclosure under Section 5.1.2
 The IPR disclosure required pursuant to Section 5.1.2 must be made as
 soon as reasonably possible after the Contribution is made, unless
 the required disclosure is already on file.
 Participants who realize that IPR meeting the conditions of Section
 5.6 may Cover technology that will be or has been incorporated into a
 Contribution, or is seriously being discussed in a working group, are
 strongly encouraged to make a preliminary IPR disclosure. That IPR
 disclosure should be made as soon after coming to the realization as
 reasonably possible, not waiting until the Contribution is actually
 made.
 If an IETF Participant first learns of IPR that meets the conditions
 of Section 5.6 that may Cover a Contribution by another party, for
 example a new patent application or the discovery of a relevant
 patent in a patent portfolio, after the Contribution is made, an IPR
 disclosure must be made as soon as reasonably possible after the
 Contribution or IPR becomes reasonably and personally known to the
 Participant.
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5.2.3. Timing of Disclosure by ADs and Others
 By the nature of their office, IETF Area Directors or persons
 assisting them may become aware of Contributions late in the process
 (for example at IETF Last Call or during IESG review) and, therefore
 in such cases, cannot reasonably be expected to disclose IPR Covering
 those Contributions until they become aware of them.
5.3. How Must an IPR Disclosure be Made?
 IPR disclosures must be made by following the instructions at
 <https://www.ietf.org/ipr-instructions>. IPR disclosures and other
 IPR-related information, including licensing information, must not be
 included in RFCs or other IETF Contributions. The RFC Editor will
 remove any IPR-related information from Contributions prior to
 publication as an RFC.
5.4. What Must Be in an IPR Disclosure?
5.4.1. Content of IPR Disclosures
 An IPR disclosure must include the following information to the
 extent reasonably available to the discloser: (a) the numbers of any
 issued patents or published patent applications (or indicate that the
 disclosure is based on unpublished patent applications), (b) the
 name(s) of the inventor(s) (with respect to issued patents and
 published patent applications), (c) the specific IETF Document(s) or
 activity affected, and (d) if the IETF Document is an Internet-Draft,
 its specific version number. In addition, if it is not reasonably
 apparent which part of an IETF Document is allegedly Covered by
 disclosed IPR, then it is helpful if the discloser identifies the
 sections of the IETF Document that are allegedly Covered by such
 disclosed IPR.
5.4.2. Updating IPR Disclosures
 Those who disclose IPR should be aware that as Internet-Drafts
 evolve, text may be added or removed, and it is recommended that they
 keep this in mind when composing text for disclosures.
 A. Unless sufficient information to identify the issued patent was
 disclosed when the patent application was disclosed, an IPR
 disclosure must be updated or a new disclosure made promptly after
 any of the following has occurred: (1) the publication of a
 previously unpublished patent application, (2) the abandonment of
 a patent application, (3) the issuance of a patent on a previously
 disclosed patent application, or (4) a material change to the IETF
 Document covered by the Disclosure that causes the Disclosure to
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 be covered by additional IPR. If the patent application was
 abandoned, then the new IPR disclosure must explicitly withdraw
 any earlier IPR disclosures based on the application. IPR
 disclosures against a particular Contribution are assumed to be
 inherited by revisions of the Contribution and by any RFCs that
 are published from the Contribution unless the disclosure has been
 updated or withdrawn.
 B. If an IPR holder files patent applications in additional countries
 which refer to, and the claims of which are substantially
 identical to, the claims of a patent or patent application
 previously disclosed in an IPR disclosure, the IPR holder is not
 required to make a new or updated IPR disclosure as a result of
 filing such applications or the issuance of patents on such
 applications.
 C. New or revised IPR disclosures may be made voluntarily at any
 other time, provided that licensing information may only be
 updated in accordance with Section 5.5.C.
 D. Any person may submit an update to an existing IPR disclosure. If
 such update is submitted by a person other than the submitter of
 the original IPR disclosure (as identified by name and email
 address), then the IETF Secretariat shall attempt to contact the
 original submitter to verify the update. If the original
 submitter responds that the proposed update is valid, the
 Secretariat will update the IPR disclosure accordingly. If the
 original submitter responds that the proposed update is not valid,
 the IETF Secretariat will not update the IPR disclosure. If the
 original submitter fails to respond after the IETF Secretariat has
 made three separate inquiries and at least 30 days have elapsed
 since the initial inquiry was made, then the IETF Secretariat will
 inform the submitter of the proposed update that the update was
 not validated and that the updater must produce legally sufficient
 evidence that the submitter (or his/her employer) owns or has the
 legal right to exercise control over the IPR subject to the IPR
 disclosure. If such evidence is satisfactory to the IETF
 Secretariat, after consultation with the IETF legal counsel, then
 the IETF Secretariat will make the requested update. If such
 evidence is not satisfactory, then the IETF Secretariat will not
 make the requested update.
5.4.3. Blanket IPR Statements
 The requirement to make an IPR disclosure is not satisfied by the
 submission of a blanket statement that IPR may exist on every
 Contribution or a general category of Contributions. This is the
 case because the aim of the disclosure requirement is to provide
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 information about specific IPR against specific technology under
 discussion in the IETF. The requirement is also not satisfied by a
 blanket statement of willingness or commitment to license all
 potential IPR Covering such technology under fair, reasonable, and
 non-discriminatory terms for the same reason. However, the
 requirement for an IPR disclosure is satisfied by a blanket statement
 of the IPR discloser's commitment to license all of its IPR meeting
 the requirements of Section 5.6 (and either Section 5.1.1 or 5.1.2)
 to implementers of an IETF specification on a royalty-free (and
 otherwise reasonable and non-discriminatory) basis as long as any
 other terms and conditions are disclosed in the IPR disclosure.
5.5. Licensing Information in an IPR Disclosure
 A. Since IPR disclosures will be used by IETF working groups during
 their evaluation of alternative technical solutions, it is helpful
 if an IPR disclosure includes information about licensing of the
 IPR in case Implementing Technologies require a license.
 Specifically, it is helpful to indicate whether, upon approval by
 the IESG for publication as an RFC of the relevant IETF
 specification(s), all persons will be able to obtain the right to
 implement, use, distribute, and exercise other rights with respect
 to an Implementing Technology a) under a royalty-free and
 otherwise reasonable and non-discriminatory license, or b) under a
 license that contains reasonable and non-discriminatory terms and
 conditions, including a reasonable royalty or other payment, or c)
 without the need to obtain a license from the IPR holder (e.g., a
 covenant not to sue with or without defensive suspension, as
 described in Section 7).
 B. The inclusion of a licensing declaration is not mandatory, but it
 is encouraged so that the working groups will have as much
 information as they can during their deliberations. If the
 inclusion of a licensing declaration in an IPR disclosure would
 significantly delay its submission, then the discloser may submit
 an IPR disclosure without a licensing declaration and then submit
 a new IPR disclosure when the licensing declaration becomes
 available. IPR disclosures that voluntarily provide text that
 includes licensing information, comments, notes, or URLs for other
 information may also voluntarily include details regarding
 specific licensing terms that the IPR holder intends to offer to
 implementers of Implementing Technologies, including maximum
 royalties.
 C. It is likely that IETF will rely on licensing declarations and
 other information that may be contained in an IPR disclosure and
 that implementers will make technical, legal, and commercial
 decisions on the basis of such commitments and information. Thus,
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 when licensing declarations and other information, comments,
 notes, or URLs for further information are contained in an IPR
 disclosure, the persons making such disclosure agree and
 acknowledge that the commitments and information contained in such
 disclosure shall be irrevocable and will attach, to the extent
 permissible by law, to the associated IPR, and all implementers of
 Implementing Technologies will be justified and entitled to rely
 on such materials in relating to such IPR, whether or not such IPR
 is subsequently transferred to a third party by the IPR holder
 making the commitment or providing the information. IPR holders
 making IPR disclosures that contain licensing declarations or
 providing such information, comments, notes, or URLs for further
 information must ensure that such commitments are binding on any
 transferee of the relevant IPR, and that such transferee will use
 reasonable efforts to ensure that such commitments are binding on
 a subsequent transferee of the relevant IPR, and so on.
 D. Licensing declarations must be made by people who are authorized
 to make such declarations as discussed in Section 5.6 of this
 document.
5.6. Level of Control over IPR Requiring Disclosure
 IPR disclosures under Sections 5.1.1 and 5.1.2 are required with
 respect to IPR (a) that is owned, directly or indirectly, by the
 individual Contributor or his/her employer or sponsor (if any), or
 (b) that such persons otherwise have the right to license or assert,
 or (c) from which such persons derive a direct or indirect pecuniary
 benefit, or (d) as to which an individual Contributor is listed as an
 inventor on the relevant patent or patent application.
5.7. Disclosures for Oral Contributions
 If a Contribution is oral and is not followed promptly by a written
 disclosure of the same material, and if such oral Contribution would
 be subject to a requirement that an IPR Disclosure be made (had such
 oral Contribution been written), then the Contributor must accompany
 such oral Contribution with an oral declaration that he/she is aware
 of relevant IPR in as much detail as reasonably possible or file an
 IPR Declaration with respect to such oral Contribution that otherwise
 complies with the provisions of Sections 5.1 to 5.6 above.
5.8. General Disclosures
 As described in Section 5.3, the IETF will make available a public
 facility (e.g., a web page and associated database) for the posting
 of IPR disclosures conforming with the disclosure requirements of
 this policy. In addition, the IETF may make available a public
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 facility for the posting of other IPR-related information and
 disclosures that do not satisfy the requirements of this policy but
 which may otherwise be informative and relevant to the IETF ("General
 Disclosures"). Such General Disclosures may include, among other
 things, "blanket disclosures" that do not contain a royalty-free
 licensing commitment as described in Section 5.4.3, disclosures of
 IPR that do not identify the specific IETF Documents Covered by the
 disclosed IPR, and licensing statements or commitments that are
 applicable generally and not to specific IPR disclosures. All of
 this information may be helpful to the IETF community, and its
 disclosure is encouraged. However, General Disclosures do not
 satisfy an IETF Participant's obligation to make IPR disclosures as
 required by this policy.
 In some cases, if an IPR disclosure submitted by an IETF Participant
 does not meet the requirements of this policy, the IETF may elect to
 post the non-conforming IPR disclosure as a General Disclosure in
 order to provide the greatest amount of information to the IETF
 community. This action does not excuse the IETF Participant from
 submitting a new IPR disclosure that conforms with the requirements
 of Sections 5.1 to 5.6. The IETF reserves the right to decline to
 publish General Disclosures that are not relevant to IETF activities,
 that are, or are suspected of being, defamatory, false, misleading,
 in violation of privacy or other applicable laws or regulations, or
 that are in a format that is not suitable for posting on the IETF
 facility that has been designated for General Disclosures.
6. Failure to Disclose
 There may be cases in which individuals are not permitted by their
 employers or by other factors to disclose the existence or substance
 of patent applications or other IPR. Since disclosure is required
 for anyone making a Contribution or Participating in IETF activities,
 a person who is not willing or able to disclose IPR for this reason,
 or any other reason, must not contribute to or participate in IETF
 activities with respect to technologies that he or she reasonably and
 personally knows may be Covered by IPR which he or she will not
 disclose, unless that person knows that his or her employer or
 sponsor will make the required disclosures on his or her behalf.
 Contributing to or Participating in IETF activities about a
 technology without making required IPR disclosures is a violation of
 IETF policy.
 In addition to any remedies or defenses that may be available to
 implementers and others under the law with respect to such a
 violation (e.g., rendering the relevant IPR unenforceable), sanctions
 are available through the normal IETF processes for handling
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 disruptions to IETF work. See [RFC6701] for details regarding the
 sanctions defined in various existing Best Current Practice
 documents.
7. Evaluating Alternative Technologies in IETF Working Groups
 In general, IETF working groups prefer technologies with no known IPR
 claims or, for technologies with claims against them, an offer of
 royalty-free licensing. However, to solve a given technical problem,
 IETF working groups have the discretion to adopt a technology as to
 which IPR claims have been made if they feel that this technology is
 superior enough to alternatives with fewer IPR claims or free
 licensing to outweigh the potential cost of the licenses. To assist
 these working groups, it is helpful for the IPR claimants to declare,
 in their IPR Declarations, the terms, if any, on which they are
 willing to license their IPR Covering the relevant IETF Documents.
 A. When adopting new technologies, the participants in an IETF
 working group are expected to evaluate all the relevant tradeoffs
 from their perspective. Most of the time these considerations are
 based purely on technical excellence, but IPR considerations may
 also affect the evaluation and specific licensing terms may affect
 the participants' opinion on the desirability of adopting a
 particular technology.
 B. The IETF has no official preference among different licensing
 terms beyond what was stated at the beginning of this section.
 However, for information and to assist participants in
 understanding what license conditions may imply, what follows are
 some general observations about some common types of conditions.
 The following paragraphs are provided for information only:
 C. When there is no commitment to license patents covering the
 technology, this creates uncertainty that obviously is concerning.
 These concerns do not exist when there is a commitment to license,
 but the license terms can still differ greatly. Some common
 conditions include 1) terms that are fair, reasonable, and non-
 discriminatory, and which may bear royalties or other financial
 obligations (FRAND or RAND); 2) royalty-free terms that are
 otherwise fair, reasonable, and non-discriminatory (RAND-z); and
 3) commitments not to assert declared IPR, possibly conditional on
 reciprocity. Open source projects, for instance, often prefer the
 latter two. Note that licenses often come with complex terms that
 have to be evaluated in detail, and this crude classification may
 not be sufficient to make a proper evaluation. For instance,
 licenses may also include reciprocity and defensive suspension
 requirements that require careful evaluation.
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 D. The level of use of a technology against which IPR is disclosed is
 also an important factor in weighing IPR encumbrances and
 associated licensing conditions against technical merits. For
 example, if technologies are being considered for a mandatory-to-
 implement change to a widely deployed protocol, the hurdle should
 be very high for encumbered technologies, whereas a similar hurdle
 for a new protocol could conceivably be lower.
 E. IETF working groups and IETF areas may, however, adopt stricter
 requirements in specific cases. For instance, the IETF Security
 Area has adopted stricter requirements for some security
 technologies. It has become common to have a mandatory-to-
 implement security technology in IETF technology specifications.
 This is to ensure that there will be at least one common security
 technology present in all implementations of such a specification
 that can be used in all cases. This does not limit the
 specification from including other security technologies, the use
 of which could be negotiated between implementations. An IETF
 consensus has developed that no mandatory-to-implement security
 technology can be specified in an IETF specification unless it has
 no known IPR claims against it or a royalty-free license is
 available to implementers of the specification. It is possible to
 specify such a technology in violation of this principle if there
 is a very good reason to do so and if that reason is documented
 and agreed to through IETF consensus. This limitation does not
 extend to other security technologies in the same specification if
 they are not listed as mandatory to implement.
 F. It should also be noted that the absence of IPR disclosures at any
 given time is not the same thing as the knowledge that there will
 be no IPR disclosure in the future, or that no IPR Covers the
 relevant technology. People or organizations not currently
 involved in the IETF or people or organizations that discover IPR
 they feel to be relevant in their patent portfolios can make IPR
 disclosures at any time.
 G. It should be noted that the validity and enforceability of any IPR
 may be challenged for legitimate reasons outside the IETF. The
 mere existence of an IPR disclosure should not be taken to mean
 that the disclosed IPR is valid or enforceable or actually Covers
 a particular Contribution. Although the IETF can make no actual
 determination of validity, enforceability, or applicability of any
 particular IPR, it is reasonable that individuals in a working
 group or the IESG will take into account their own views of the
 validity, enforceability, or applicability of IPR in their
 evaluation of alternative technologies.
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8. Change Control for Technologies
 The IETF must have change control over the technology described in
 any Standards Track IETF Documents in order to fix problems that may
 be discovered or to produce other derivative works.
 In some cases, the developer of patented or otherwise controlled
 technology may decide to hand over to the IETF the right to evolve
 the technology (a.k.a., "change control"). The implementation of an
 agreement between the IETF and the developer of the technology can be
 complex. (See [RFC1790] and [RFC2339] for examples.)
 Note that there is no inherent prohibition against a Standards Track
 IETF Document making a normative reference to proprietary technology.
 For example, a number of IETF standards support proprietary
 cryptographic transforms.
9. Licensing Requirements to Advance Standards Track IETF Documents
 Section 2.2 of RFC 6410 [RFC6410] states:
 If the technology required to implement the specification requires
 patented or otherwise controlled technology, then the set of
 implementations must demonstrate at least two independent,
 separate and successful uses of the licensing process.
 A key word in this text is "requires". The mere existence of
 disclosed IPR does not necessarily mean that licenses are actually
 required in order to implement the technology.
10. No IPR Disclosures in IETF Documents
 IETF Documents must not contain any mention of specific IPR. All
 specific IPR disclosures must be submitted as described in Section 5.
 Readers should always refer to the online web page
 <https://www.ietf.org/ipr/> to get a full list of IPR disclosures
 received by the IETF concerning any Contribution.
11. Application to Non-IETF Stream Documents
 This document has been developed for the benefit and use of the IETF
 community. As such, the rules set forth herein apply to all
 Contributions and IETF Documents that are in the "IETF Document
 Stream" as defined in Section 5.1.1 of [RFC4844] (i.e., those that
 are contributed, developed, edited, and published as part of the IETF
 Standards Process).
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 The rules that apply to documents in Alternate Streams are
 established by the managers of those Alternate Streams (currently the
 Internet Architecture Board (IAB), Internet Research Steering Group
 (IRSG), and Independent Submission Editor, as specified in
 [RFC4844]). These managers may elect, through their own internal
 processes, to cause this document to be applied to documents
 contributed to them for development, editing, and publication in
 their respective Alternate Streams. If an Alternate Stream manager
 elects to adopt this document, they must do so in a manner that is
 public and notifies their respective document Contributors that this
 document applies to their respective Alternate Streams. In such
 case, each occurrence of the term "Contribution" and "IETF Document"
 in this document shall be read to mean a contribution or document in
 such Alternate Stream, as the case may be. It would be advisable for
 such Alternate Stream managers to consider adapting the definitions
 of "Contribution" and other provisions in this document to suit their
 particular needs.
12. Security Considerations
 This document relates to the IETF process, not any particular
 technology. There are security considerations when adopting any
 technology, whether IPR protected or not. A working group should
 take those security considerations into account as one part of
 evaluating the technology, just as IPR is one part, but there are no
 known issues of security with IPR procedures.
13. Changes since RFCs 3979 and 4879
 The material in RFC 3979 was significantly reorganized to produce
 this document. This section reviews the actual changes in content
 since RFC 3979 and does not detail the reorganization. These changes
 are listed from the point of view of this document with reference to
 the RFC 3979 section where useful. This section is intended only as
 an informational summary of the text contained in Sections 1-12 of
 this document. This section does not constitute the official policy
 of the IETF and should not be referred to or quoted as such. Any
 discrepancies or ambiguities shall be resolved in favor of the
 language contained in Sections 1-12 of this document.
 Boilerplate - Since the document boilerplate formerly in Section 5 of
 RFC 3979 has been moved to the Trust Legal Provisions since 2009,
 the boilerplate requirements have been deleted from this document.
Bradner & Contreras Best Current Practice [Page 20]
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 1 - Definitions
 1.a - "Alternate Stream" definition (new): Added to enable IRTF,
 IAB, and Independent Submission streams to adopt and use BCP 79
 more easily.
 1.c - "Contribution" (was 1.c)
 Removed "IETF" to more easily enable other Streams to adopt
 this policy.
 Added "intended to affect the IETF Standards Process", which
 is needed to prevent information presentations (e.g.,
 plenary guest speakers) from being considered Contributions.
 Added BOF, design team, web site, and chat room.
 Contributions can be made in any of these places.
 1.e - "Covers" (was 1.n) - Added "provisional patent application"
 - Required to eliminate ambiguity whether provisional
 applications are included.
 1.h - "IETF Documents" (was 1.h) - Limited to IETF (not Alternate
 Stream) documents.
 1.i - "IETF Standards Process" (was 1.b) - Clarify that
 Contributions can be made in contexts other than traditional
 IETF standards development.
 1.j - "IPR" (was 1.o) - Removed reference to copyrights, database
 rights, and data rights. Copyright in IETF Documents and
 contributions is addressed under RFC 5378 and is treated very
 differently than patents, which are the focus of BCP 79.
 Data/database rights not relevant to IETF standards, and cannot
 be registered or disclosed in the manner of patents.
 1.l - "Internet-Draft" (was 1.g) - Reduced to reference RFC 2026
 without additional description for clarity.
 1.m - "Participating in an IETF discussion or activity" (new) -
 Due to numerous ambiguities over the years, it was necessary to
 add a section describing what it means to "participate" in an
 IETF activity.
 1.o - "RFC" (was 1.e) - Added cross-reference to RFC 2026 and
 eliminated textual description of RFC permanence.
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 2 - Introduction - Added text that offers an overview of why we have
 this policy, cut prior discussion of Section 10 of RFC 2026 as no
 longer necessary, and added references to subsequent RFCs relating
 to IPR, including RFC 5378 and 6702.
 3 - Participation in the IETF (was "Contributions to the IETF") -
 Changed focus to participation rather than making of Contributions
 and explained why we require IPR disclosure.
 old 3.2.1.C - Deleted because all required legends in IETF Documents
 are now described in RFC 5378 and Trust Legal Provisions.
 3.3 - Obligations on Participants - Added to make clear that
 participation in IETF obligates the participant to comply with
 IETF rules.
 old 4.A - Removed because inconsistent with current and historical
 practice. Also, all legends in IETF Documents are now addressed
 in Trust Legal Provisions.
 4.A - "The IESG, IAB..." - Added IAB, ISOC, and IETF Trust to
 disclaimer.
 4.B - "When the IETF Secretariat..." - Added description of current
 procedure used to publish third party IPR disclosures.
 4.C - "When an IPR disclosure..." - Updated to reflect current
 practice and roles (e.g., Secretariat rather than IETF Exec Dir).
 4.D - Determination of Provision of Reasonable and Non-discriminatory
 Terms (was Section 4.1) - Various edits made to this paragraph to
 reflect current process for advancement of standards.
 old 5 - Deleted because it was not needed.
 5.1.1 - Contributor's IPR in His or Her Contribution (was Section
 6.1.1) - Limits disclosure obligation to written Contributions
 intended to be used as inputs to the IETF Standards Process. Oral
 disclosures are now covered in Section 5.7.
 5.1.2 - An IETF Participant's IPR in Contributions by Others (was
 Section 6.1.2) - Revisions made consistent with Section 5.1.1
 above.
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 5.1.3 - Voluntary IPR Disclosures (was Section 6.1.3) - Fixes
 procedures for making voluntary IPR disclosures and adds examples
 of when voluntary disclosures may be appropriate. In addition to
 IPR of others, voluntary disclosures are encouraged when an IETF
 Participant is aware of its own IPR that covers IETF work in which
 it is not an active participant and when the technology is
 disclosed in other than an IETF setting.
 5.2.1 - Timing of Disclosure under Section 5.1.1 (was Section 6.2.1)
 - Trigger for disclosure changed from publication of a
 Contribution in an I-D to "submitted or made"; lengthy example
 regarding updates deleted in lieu of cross-reference to Section
 5.4.2 regarding updates.
 5.2.2 - Timing of Disclosure under Section 5.1.2 (was Section 6.2.2)
 - Corresponding changes made per Section 5.2.1.
 5.2.3 - Timing of Disclosure by ADs - Added to clarify AD disclosure
 obligations.
 5.3 - "IPR disclosures and other..." - Reflects current practice
 regarding prohibition of including IPR information directly in
 IETF Documents.
 5.4.1 - Content of IPR Disclosures (was Section 6.4.1) - Added
 requirement to disclose names of inventors - Disclosing the
 name(s) of inventors on a patent will make it more likely that
 IETF Participants will recognize whether the inventor is an IETF
 Participant and what IETF activities that individual participates
 in. This information is easy for the discloser to provide and
 less convenient for every reader of the IPR disclosure to look up
 in patent office records (if even available).
 5.4.2 - Updating IPR Disclosures (was Section 6.4.2) - Significant
 revisions and additional detail added regarding updating of IPR
 disclosures upon events such as issuance of patents, amendment of
 claims, employee changing jobs, employer acquires another company,
 etc.
 5.4.2.D - Clarify that additional IPR disclosures are not needed for
 foreign counterparts.
 5.4.3 - Blanket IPR Statements (was Section 6.4.3) - wording
 clarifications and changed "willingness" to "commitment". A
 blanket IPR disclosure which does not list specific patent numbers
 is not compliant with this policy unless the discloser commits
 (and is not just willing) to license such patents on royalty-free
 and otherwise reasonable terms.
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 5.5.C - "It is likely that IETF will rely ..." (new paragraph) -
 Makes licensing declarations irrevocable so that they may be
 relied upon in the future by implementers.
 5.5.D - "Licensing declarations ..." (new paragraph) - Requires that
 licensing declarations must be made by people authorized to make
 them.
 5.6 - Level of Control over IPR Requiring Disclosure (was Section
 6.6) - In addition to ownership of IPR, language added to require
 disclosure when Participants derive a pecuniary benefit from the
 IPR, or the individual is a listed inventor - Clarifications to
 address situations not covered in earlier version.
 5.7 - Disclosures for Oral Contributions (new): Describes procedure
 for oral Contributions. Previously, statements regarding oral
 statements were contradictory. Some places said that disclosures
 must be made for oral statements, but others talk about
 disclosures only being required following publication as an I-D.
 Under new text, oral statements don't trigger the normal IPR
 disclosure obligations, as oral statements are inherently
 imprecise and it's hard to know when they describe something
 covered by the technical terms of a patent claim. However, if an
 oral contribution is made and it is not followed by a written
 contribution, then the oral discloser must either make a
 concurrent oral IPR disclosure or file a formal written
 disclosure.
 5.8 - General Disclosures (new) - Describes the IETF's public
 disclosure feature, which allows IPR disclosures to be made by
 anyone, whether or not an IETF Participant. The feature has been
 up and running for years, and this language describes its current
 implementation.
 6 - Failure to Disclose (was Section 7) - Technical and clarity
 corrections, as well as new language describing potential remedies
 for failures to disclose IPR in accordance with IETF rules,
 including IESG actions described in RFC 6701.
 7 - Evaluating Alternative Technologies in IETF Working Groups (was
 Section 8).
 Paragraph 1 - Minor wording changes for clarity.
 Paragraphs 2-5 (new) - Relate to the considerations made by IETF
 WGs when evaluating patent and licensing disclosures
 concerning IETF standards.
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 Paragraph 6 - security technologies (new) - Makes clear that
 security is only one example of stricter requirements. Also
 requires that violation of requirements for royalty-free
 licensing in the security area can be made only with IETF
 consensus.
 Paragraphs 7-8 (were paragraphs 3-4) - Wording changes for
 clarity.
 9 - Licensing Requirements to Advance Standards Track IETF Documents
 (was Section 10) - Wording updated to reflect RFC 6410.
 10 - No IPR Disclosures in IETF Documents (was Section 11) - Wording
 simplified to refer to Section 5.
 11 - Application to Non-IETF Stream Documents (new) - Adds procedures
 to be followed by Alternate Stream (IAB, IRTF, Independent
 Submission) managers to adopt these rules and procedures.
 Borrowed and adapted the copyright language used in the Trust
 Legal Provisions. Each Alternate Stream (Independent Submission,
 IRTF, and IAB) would need to take some action (preferably issuing
 an RFC) to adopt BCP 79 for its stream. This was done with
 copyright already, and pretty smoothly.
14. References
14.1. Normative References
 [RFC2026] Bradner, S., "The Internet Standards Process -- Revision
 3", BCP 9, RFC 2026, DOI 10.17487/RFC2026, October 1996,
 <http://www.rfc-editor.org/info/rfc2026>.
 [RFC2028] Hovey, R. and S. Bradner, "The Organizations Involved in
 the IETF Standards Process", BCP 11, RFC 2028,
 DOI 10.17487/RFC2028, October 1996,
 <http://www.rfc-editor.org/info/rfc2028>.
 [RFC4844] Daigle, L., Ed., and Internet Architecture Board, "The RFC
 Series and RFC Editor", RFC 4844, DOI 10.17487/RFC4844,
 July 2007, <http://www.rfc-editor.org/info/rfc4844>.
 [RFC6410] Housley, R., Crocker, D., and E. Burger, "Reducing the
 Standards Track to Two Maturity Levels", BCP 9, RFC 6410,
 DOI 10.17487/RFC6410, October 2011,
 <http://www.rfc-editor.org/info/rfc6410>.
Bradner & Contreras Best Current Practice [Page 25]
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14.2. Informative References
 [RFC1790] Cerf, V., "An Agreement between the Internet Society and
 Sun Microsystems, Inc. in the Matter of ONC RPC and XDR
 Protocols", RFC 1790, DOI 10.17487/RFC1790, April 1995,
 <http://www.rfc-editor.org/info/rfc1790>.
 [RFC2339] The Internet Society and Sun Microsystems, "An Agreement
 Between the Internet Society, the IETF, and Sun
 Microsystems, Inc. in the matter of NFS V.4 Protocols",
 RFC 2339, DOI 10.17487/RFC2339, May 1998,
 <http://www.rfc-editor.org/info/rfc2339>.
 [RFC5378] Bradner, S., Ed., and J. Contreras, Ed., "Rights
 Contributors Provide to the IETF Trust", BCP 78, RFC 5378,
 DOI 10.17487/RFC5378, November 2008,
 <http://www.rfc-editor.org/info/rfc5378>.
 [RFC6701] Farrel, A. and P. Resnick, "Sanctions Available for
 Application to Violators of IETF IPR Policy", RFC 6701,
 DOI 10.17487/RFC6701, August 2012,
 <http://www.rfc-editor.org/info/rfc6701>.
 [RFC6702] Polk, T. and P. Saint-Andre, "Promoting Compliance with
 Intellectual Property Rights (IPR) Disclosure Rules",
 RFC 6702, DOI 10.17487/RFC6702, August 2012,
 <http://www.rfc-editor.org/info/rfc6702>.
Editors' Addresses
 Scott Bradner
 15 High St.
 Cambridge, MA 02138
 United States of America
 Phone: +1 202 558 5661
 Email: sob@sobco.com
 Jorge Contreras
 University of Utah
 S.J. Quinney College of Law
 383 South University St.
 Salt Lake City, UT 84112
 United States of America
 Email: cntreras@gmail.com
Bradner & Contreras Best Current Practice [Page 26]