How to derive and apply aggregate royalty rates for SEP FRAND determinations. I have previously argued against the Commissions apparent intention to abandon the established approach of using comparable licensing agreements as benchmarks in determining FRAND royalty rates and instead use the top-down approach with patent counting to apportion royalties among SEP licensors.
WIS
WiseHarbor
Company · United Kingdom
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts — staff, costs, accreditations — are not available for it.
3
positions filed
in the 583 files tracked
1
legislative file
of 583 tracked
3
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
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Their record over time
WiseHarbor filed 3 positions between 3 May 2022 and 8 Aug 2023, across 1 of the 583 legislative files tracked here, attaching a full position paper 3 times.
2022 · 1 filed2023 · 2 filed
What they argued
I, Keith Mallinson, am the founder and managing partner of WiseHarbor, an industry analyst research firm focusing on markets for products and services that rely on telecommunications technologies. For 15 years, WiseHarbor has also specialized in SEP and FRAND licensing issues.
The Commission’s call for evidence myopically misses the bigger question of how to restore—in 5G and 6G—Europe’s former leadership for a decade around the millennium with 2G GSM in communications-based technologies, products and services.
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