IP Maximalists

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IP Maximalists are those who want to strengthen Intellectual Property protections to the maximum amount possible, to protect private monopoly interests, in disregard of any human cost, such as the millions who die from too expensive IP-protected medecines.

Source: overview by Prof. Susan K. Sell, [email protected]


URL = http://www.twnside.org.sg/title2/intellectual_property/development.research/SusanSellfinalversion.pdf

Background on IP Maximalist Tactics

Some excerpts:

1. Relentless search for non-participative institutional forums

“Proponents of an IP maximalist agenda increasingly have been rebuffed in recent years. Developing country governments, NGOs, and Access to Knowledge (A2K) advocates have thwarted their efforts to ratchet up standards of intellectual property protection in multilateral intergovernmental forums such as the World Trade Organization, the World Intellectual Property Organization, and the World Health Organization. A2K advocates challenge the premises behind ever higher and broader intellectual property protection and seek, if not a rolling back of IP rights, at the very least a standstill. They argue that in the balance between rights and obligations, IP maximalists assert their rights without recognizing their obligations. IP maximalists always have seen TRIPS as a floor, not a ceiling. Ever since the WTO TRIPS negotiations that ended in 1994, they have been using every opportunity to increase intellectual property protection and enforcement beyond TRIPS. They have been relentless, focused, and have devoted untold resources to their quest for higher global standards of intellectual property protection and enforcement. Undaunted by recent setbacks at the multilateral level, IP maximalists have launched a major, almost surreptitious, anti-A2K campaign focused on “counterfeiting”, “piracy” and “enforcement”.

Since the early 1980s advocates of a maximalist IP agenda have shifted forums both horizontally and vertically in order to achieve their goals. Those who seek to ration access to IP are engaged in an elaborate cat and mouse game with those who seek to expand access. As soon as one venue becomes less responsive to a high protectionist agenda, IP protectionists shift to another in search of a more hospitable venue. As Peter Drahos points out, developing country negotiators, NGOs, and A2K advocates must adopt a longitudinal perspective on IP negotiations or they will risk winning small battles (e.g., the Doha Declaration) but losing the war (e.g., access to affordable medicines).According to Drahos, “forum shifting means that some negotiations are never really over.” Strong states like the U.S. shift forums to optimize their power and advantages and minimize opposition. The IP enforcement agenda is just the latest in a series of strategic forum shifts.

IP-based firms, with their supportive governments, seek to go far beyond TRIPS in IP enforcement. Their four main goals are to: document and explain the value of IP; ensure strong government support for IP in the US; rally allied nations and organizations to defend IP; and hold anti-IP governments accountable. For instance, under the proposed Anti-Counterfeiting Treaty (ACTA) they would like to see all countries sign on to the WIPO Copyright Treaty and the WIPO Performances and Phonograms Treaty (WPPT); together they are referred to as the “Internet Treaties.” Enforcement provisions under these treaties include legal remedies against circumvention of technological protection measures (e.g., encryption) or deletion of electronic rights management information. Since many countries have not signed on to these treaties, the efforts to have everyone sign would raise IP standards and reduce some states’ flexibilities in IP policy. For economically advanced countries like Canada, IP-based firms would like to see them go beyond the TRIPS-Plus WIPO treaties and adopt something similar to the US Digital Millennium Copyright Act (DMCA). The ACTA would run roughshod over differences across jurisdictions. (e.g., many countries have yet to sign on to the WIPO Internet Treaties). The following section provides a brief institutional roadmap to the complex and comprehensive process underway.”

2. Politics of fear

“Advocates of the IP enforcement agenda have engaged in a shrill public relations campaign to frighten people into accepting their agenda. At a CropLife America meeting on December 1st 2007 Dan Glickman, head of the Motion Picture Association, recommended that advocates underscore the danger of counterfeited and pirated goods. Through fear mongering, IP enforcement agenda advocates are constructing a big tent that includes all types of intellectual property: trademarks, patents, copyrights. Despite the very real differences between all the types of intellectual property contained in the IP enforcement agenda’s “big tent” approach, there is one thing that Kate Spade bags and pharmaceuticals DO have in common and that is high prices. High prices are directly related to the demand for counterfeit products. This campaign is characterized by strategic obfuscation; its message is intentionally misleading. For example, it is difficult to imagine a “dangerous” counterfeit handbag, or a “dangerous” dvd.

The fear mongering ranges from tales of exploding cell phones and toxic counterfeit drugs, to unsubstantiated allegations of organized crime and even terrorist involvement.

The IP enforcement agenda advocates have promoted two sensationalist books, Illicit: How Smugglers, Traffickers, as Copycats are Hijacking the Global Economy and Knockoff: the Deadly Trade in Counterfeit Goods.The ICC funded a public broadcast of a program based on Illicit, which equates counterfeiting with human smuggling, drug smuggling, small arms trafficking, and black market trade in nuclear materials.

The big tent approach to “counterfeiting” and “piracy” is designed to capture behavior that is legal.” (http://www.twnside.org.sg/title2/intellectual_property/development.research/SusanSellfinalversion.pdf)

What can we do to counter such tactics?

Susan K. Sell recommends:

“Is there any way to stop the IP rights holders’ juggernaut of ever higher levels of protection and enforcement?

I present several possibilities below.

First, one should insist that IP enforcement proponents define terms such as trademark counterfeiting and copyright piracy quite explicitly. As Outterson and Ryan suggested, it is important to clarify terminology and explicitly distinguish between and create different sets of rules for counterfeited goods, pirated goods, grey goods, parallel imports, generic goods, and goods produced under TRIPS-compliant compulsory licenses.

It is also imperative to identify and target policymakers and industry representatives who are sympathetic to the A2K agenda. Some members of the US Congress have been supportive, and the European Parliament has injected some balance into EU policies.

The OECD is another potential venue to lobby against this IP enforcement agenda. Also, despite the USCC approach, many successful and powerful business firms have good reason to object to the IP enforcement agenda.

Many IT firms have been lobbying Congress to roll back patent protection in their industry because of the so-called” patent troll” problem.

The hypocrisy of the campaign must be highlighted. For instance, the MPA always emphasizes its interest in preserving American jobs. Indeed, when you watch a Hollywood dvd you get to see the FBI anti-piracy notice, and sometimes the brief testimonials of caterers, stunt people, make up artists, and camera people claiming that downloading movies illegally costs them their jobs. MPA is always telling Congress how many American jobs counterfeiting costs Hollywood.

Yet MPA does huge amount of filming in Canada due to lower production costs and generous subsidies; Hollywood unions have tried to sue MPAA for taking jobs out of the country. As Lee points out, “in a 2000 report, the US Department of Commerce estimated that this ‘runaway production’ to Canada resulted in production losses of $2 billion to the U.S. economy in 1999.” Thus, despite the sometimes seemingly altruistic rhetoric, MPA “lobbies for the interests of its own members, even when doing so appears to go against the interests of the U.S. economy.”

Furthermore, films and music, and even apparel, do not fit in to the “danger” trope, even though US State Department ads about dangerous counterfeits (e.g. pills, exploding cell phones, faulty electrical cords, failing care brakes, and DVDs?!) include images of dvds.. Also, it is reasonable to assume that Microsoft would prefer that poor people use bootleg Microsoft software rather than Linux, in order to get them hooked on the Windows platform. Monsanto just might not mind the unauthorized transfer of GMO seeds across borders from Argentina to Brazil to circumvent biosafety regulations, because once the proverbial cat is out of the bag it is hard to go back.

Hypocrisy is also evident in the narrative that counterfeits cause injury. According to the USPTO-commissioned study on the subject, governments are obligated to protect public health. Yet IP enforcement agenda advocates actively oppose government efforts to protect public health when it comes to compulsory licensing and parallel imports, even when millions of patients are at risk of death.

Clearly, in this field, evidence-based empirical analysis is necessary to counter some of the more outlandish claims advanced in support of this enforcement agenda. The current ACTA push is based on highly suspect data. The IP enforcement agenda advocates’ use of data can be creative. For example, while BASCAP claims that worldwide losses to counterfeiting and piracy amount to $600 billion per year, $250 billion in the U.S. alone, the more sober yet still supportive OECD estimates that worldwide trade in counterfeit and pirated goods is closer to $200 billion per year.The IIPA quoted one study as estimating lost tax revenue in the US to be $2.6 billion in 2006. Many IP enforcement agenda advocates rely on just one economist, who continues to produce reports that echo the ACTA lobbyists’ narrative. Steve Siwek provides figures for IIPA, and Institute for Policy Innovation, RIAA, and MPAA with his “True Cost of Piracy” series. Siwek has conducted over 11 studies for industry and also helped to formulate methodology for WIPO to calculate the copyright industries’ role in all economies. Figures provided by self-interested industry lobbyists can be inflated, by assuming, for example, that one may calculate lost revenue based on the differential between the full retail price of a good and the lower price of the “knockoff.” Yet often those who buy the cheaper version could not afford to pay the full retail price and would not buy it if the knockoff were unavailable. Thus the industry-generated numbers are unreliable guides for policymaking. Finally while the danger rhetoric is sensational, a USPTO commissioned study on injuries and counterfeit goods concluded that over 60% of counterfeit seizures have nothing to do with health or safety.Independent studies must be conducted by economists who are not on industry’s payroll and who will not be tempted or obligated to inflate numbers.

Finally, it is important to emphasize that “enforcement” is not a one-sided concept. Enforcement means not only enforcing IP holders’ rights, but it also means enforcing balance, exceptions and limitations, fair use, civil rights, privacy rights, and antitrust (or competition policy).”

Overview of Organizations

The main actors in the ACTA process are “nodal actors” or networks of state and private sector actors who coordinate their positions and enroll nodal actors to help the cause. These are not single issue coalitions of states, but rather a mélange of private and public sector actors who share compatible goals and continue to coordinate their negotiating positions over time and across forums. Drahos states that “there is considerable evidence that the US runs its trade negotiation as a form of networked governance rather than as a simple process of domestic coalition building.”[12] The anti-counterfeiting and enforcement agenda represents densely networked governance. Among the actors that this network recently has enlisted are the World Customs Organization, the US Department of Homeland Security, and Interpol.

Campaign to Protect America

This campaign is the USCC’s Coalition against Counterfeiting and Piracy’s Intellectual Property Enforcement Initiative. This initiative lays the groundwork for all of the other efforts because it is comprehensive, and outlines the full court press strategy that industry and supportive government agencies currently are pursuing. While it is US-based, it offers significant insights into the broader global strategy because the US has been the first mover and major instigator of the quest for ever higher IP standards. Many of the initiatives that follow fit neatly under this broader rubric. The campaign includes a number of ambitious goals. The campaign presents six initiatives. I will discuss each in turn. First, is to improve coordination of federal government intellectual property enforcement resources. To this end, the campaign sought to designate a chief IP enforcement officer (“IP czar”) within the White House. The US House of Representatives passed this provision, in the Prioritizing Resources and Organization for Intellectual Property Act (PRO-IP) in May 2008.It awaits the Senate vote. The campaign also sought to raise anti-counterfeiting and piracy responsibilities to senior levels at the Department of Justice and Department of Homeland Security.

In 2004 the White House initiated its Strategy Targeting Organized Piracy STOP! This has focused on interagency coordination. The US has established the National Intellectual Property Enforcement Council. Its members include the U.S. Coordinator for International IP Enforcement and high level officers from the Departments of Commerce, Homeland Security, Justice, State, and USTR. The US Copyright Office serves as an advisor to the Council.

The second initiative focuses on border protection against counterfeiting and piracy. This involves expanding information-sharing capabilities, developing databases to flag suspect shipments, to fund more agents and training programs, to give Customs and Border Protection agents more legal authority “to audit and assess fines for importers, exporters, or other parties that materially facilitate the unlawful entry of counterfeit and pirated goods into the US.” This raises important questions because what constitutes a “counterfeit” or “pirated” product varies from jurisdiction to jurisdiction. These are complex legal issues that Customs officers are neither trained nor authorized to adjudicate. Border protection goals include eliminating the existing “personal use” exemption and outlawing importation of any quantity of counterfeit or pirated products including via mail or courier service.[17] These goals could impact the fair use doctrine, or allowances for infringements for noncommercial purposes.

The third initiative addresses enhanced law enforcement capacities to crack down on “intellectual property theft” by increasing funding for law enforcement (US Attorneys’ Offices, FBI, training for state and local law enforcement), enhancing penalties for counterfeiters who cause bodily injury or death, and increasing coordination between law enforcement and industry.

The fourth initiative to “Protect America” is to coordinate with law enforcement and customs officials across borders and abroad. Activities include training and technical assistance. USTR and industry are, together, to devise and coordinate priorities for technical assistance. Public-private partnerships feature prominently. It also involves funding “technical assistance” to train governments in IP enforcement, establish IP attaches at US embassies, and increase funding for Intellectual Property Law Enforcement Coordinators internationally. Again, in conjunction with USTR, the initiative endorses the use of the Generalized System of Preferences (GSP) and regional trade preference programs to encourage enforcement of IP rights.

Fifth, “Protect America” seeks to establish a pilot program for judges to handle counterfeiting and piracy cases, and institute treble damages against complicit activity related to counterfeiting.

Finally, “Protect America” seeks to create and administer a nation-wide consumer awareness campaign revealing the harms caused by counterfeiting and piracy (including paid and donated ads for television, radio, print, and the Internet).[20] It also seeks to focus on college campuses to fund R&D to secure campus networks against P2P network activity, and to direct funding agencies to favor those campuses that have the most stringent antipiracy practices.

Industry associations and the USTR

Associations such as Motion Picture Association, the Recording Industry Association of America, the International Intellectual Property Alliance, and the Business Software Alliance routinely provide data and information about foreign governments’ failure adequately to protect their intellectual property. They submit reports and complaints through the Special 301 process and USTR names alleged offenders on its annual Watch Lists.

According to law professor Michael Geist, “Canadian officials have ‘rightly dismissed’ the Special 301 process as ‘little more than a lobbying exercise.’ … One official told a parliamentary committee that Canada does not recognize the process because it ‘lacks reliable and objective analysis’ and is ‘driven entirely by US industry.’” The 2008 Watch List identified China, Russia, and Thailand as among the worst offenders. Significantly, China’s placement on the Priority Watch List is due to concerns about enforcement. The US has filed a complaint against China with the WTO; this will be the first WTO dispute focused on enforcement. Industry, through the USTR, is pressuring Russia to adopt TRIPS-Plus measures as part of its WTO accession process.

On October 23rd 2007, just two weeks after WIPO’s September 2007 adoption of the Development Agenda, USTR Susan Schwab announced that it would seek to negotiate ACTA in order to “set a new, higher benchmark for enforcement that countries can join on a voluntary basis.” Kevin Havelock, president of Unilever United States noted that Schwab ‘’made quite a commitment of her own energy’ pushing for ACTA.”On that same day, the Ministry of Foreign Affairs of Japan and the European Commission announced their intentions to pursue an international enforcement agreement. Notably this process will go forward independently of any international organization. Indeed, Eric Smith, head of IIPA, reflects industry’s determination for an uncompromising agreement when he states that the ambitious agreement for strengthened enforcement “should not be sacrificed for additional signatories or the need for a hurried conclusion of negotiations.”

Industry-dominated groups in International Organizations

WIPO: the Advisory Committee on Enforcement (ACE), established in 2002 is industry dominated, and has devoted its efforts to discussing strengthening enforcement and problems that rights holders face in third countries. ACE has not devoted attention to public interest considerations or rights holders’ obligations.

The World Health Organization’s International Medicinal Products Anti-Counterfeit Taskforce (IMPACT) is supported by the International Federation of Pharmaceutical Associations (IFPMA). Interpol is deeply involved in this effort and has focused its efforts in Southeast Asia. Other members include representatives of WIPO, OECD, WTO, and WCO. Government participation is voluntary; IMPACT tends to be industrydominated, and according to Outterson and Ryan, industry tends to blur the distinctions between parallel trade, compulsory licenses, and generics. Critics question this initiative, which is a G8 priority that focuses on counterfeit drugs rather than other pressing health issues.

Industry is very involved in monitoring the WTO accession process, and is pressing to make enforcement a permanent part of the TRIPS Council agenda.


While copyright and trademark-based industries have been concerned about enforcement for many years, the most recent push for a new approach emerged in 2004 at the first annual Global Congress on Combating Counterfeiting. The Global Business Leaders’ Alliance Against Counterfeiting (GBLAAC), whose members include Coca Cola, Daimler Chrysler, Pfizer, Proctor and Gamble, American Tobacco, Phillip Morris, Swiss Watch, Nike, and Canon, sponsored the meeting in Geneva.Interpol and WIPO hosted the meeting. At the July 2005 Group of 8 (G8), meeting Japanese representatives suggested the development of a stricter enforcement regime to battle “piracy and counterfeiting.” The G8 issued a postmeeting statement: “Reducing IP Piracy and Counterfeiting Through More Effective Enforcement.” In what would become a familiar trope, the first line claims that trade in counterfeit and pirated goods “can have links to organized crime,” and threatens employment, innovation, economic growth, and public health and safety. That same year, the US Council of International Business partnered with the International Chamber of Commerce to launch the Business Coalition to Stop Counterfeiting and Piracy (BASCAP).

A recently leaked discussion paper about ACTA circulated among industry insiders and government negotiators from the US, Japan, Switzerland, Canada, the European Union, Australia, Mexico, South Korea, and New Zealand included all of these negative effects and added “loss of tax revenue” to the litany.

This is no high-minded quest for the public good. As David Fewer of the Canadian Internet Policy and Public Interest Clinic and the University of Ottawa noted, “if Hollywood could order intellectual property laws for Christmas what would they look like? This is pretty close.”One of the central features of ACTA’s approach would be to enlist the public sector in enforcing private rights. This means that tax payers’ dollars would be used to protect private profits. The opportunity costs of switching scarce resources for border enforcement of IP “crimes” is huge. There surely are more pressing problems for law enforcement in developing countries than ensuring profits for OECD-based firms. Other concerns address the lopsided nature of the ACTA approach, favoring rights holders above all else and presuming suspects to be guilty. Due process of law will be sacrificed to the interests of IP rights holders and there will be few, if any, checks on abuses of rights.[38] It would authorize border guards and customs agents to search laptops, iPods, and cell phones for infringing content. Customs officials would have authority to take action against suspected infringers even without complaints from rights holders; they could confiscate the laptops and iPods. Privacy issues arise over extensive data sharing and possible wire tapping that could be involved in ramped up enforcement efforts.

ACTA would require Internet Service Providers to police and control their systems for infringing content.[39] Its one-size fits all policy exacerbates the problems that even the far more forgiving and flexible TRIPS revealed. It sharply reduces policy space for developing countries to design appropriate policies for their public policy for innovation and economic development. It also would create an additional international intellectual property governance layer atop an already remarkably complex and increasingly incoherent intellectual property regime.

As Shaw points out, “instead of merely shifting the debate from one forum to another, the ACTA supporters now seek to create an entirely new layer of global governance.” The treaty will be tabled at the G8 meeting in Tokyo in July 2008.

World Customs Organization

The G8 opened negotiations at WCO to establish customs enforcement standards. In June 2006 Members recognized the major role that they could play in IP protection, and established a set of standards for IP enforcement.[42] Brussels-based WCO is a congenial forum for IP rights holders because there they are on equal footing with governments.

Discussions at WCO have not been transparent, and advocacy and consumer groups have not been able to participate; many suspect that “rich country governments view it as a forum where they can strive for new IP rules, free from scrutiny.” The provisional Standards to be Employed by Customs for Uniform Rights Enforcement (SECURE), dramatically expand the scope and level of enforcement protections beyond TRIPS, leading some commentators to refer to these as Trips-Plus-Plus standards. At its third meeting of the Working Group on SECURE the WCO Secretariat announced that consultations on SECURE had been completed, with an eye toward adopting SECURE at its June 2008 meeting.

SECURE is Trips-Plus-Plus because it: extends the scope from import to export, transit, warehouses, transshipment, free zones, and export processing zones; extends protection from trademark and copyright to all other types of IP rights; removes the obligations of rights holders to provide adequate evidence that there is prima facie an infringement to initiate a procedure; requires governments to designate a single authority as a contact point for Customs; gives Customs administrations the legal authority to impose deterrent penalties against entities knowingly involved in the export or import of goods which violate any IPR laws (versus just trademark counterfeiting and copyright piracy).

The IP enforcement agenda’s nodal network has enlisted the WCO to champion IP protection and to pursue an expanded mandate. SECURE privileges IP rights holders, and while at this moment adopting SECURE is voluntary, these TRIPS-Plus-Plus provisions are likely to appear in bilateral and regional trade and investment treaties.[47] One can expect this given the US and EU track record of norm-setting, and then institutionalizing Trips-Plus provisions into Bilateral Investment Treaties, Free Trade Agreements, and EPAs.[48] Thus even though “the WCO lacks the authority to set or enforce policies that contradict the WTO,”[49] TRIPS specifies that member states are free to adopt IP protection and enforcement standards that exceed TRIPS provisions; therefore if states adopt SECURE provisions in bilateral or regional agreements they will not be contradicting WTO. WCO works with WIPO, Interpol, OECD, the European Commission, WHO, and the Council of Europe to coordinate its activities. Brazil has been an outspoken critic of these measures as setting a dangerous precedent and of sneaking in TRIPS-Plus-Plus provisions “’through the backdoor.’”


Interpol increasingly has gotten involved in IP enforcement. It has been a prominent participant in the Annual Global Congresses Combating Counterfeiting & Piracy.

Interpol, WCO, WIPO, International Trademark Association, International Chamber of Commerce, and the International Security Management Association co-sponsor the Congresses, which have become an important global forum for government officials and IP rights holders to exchange information, best practices, and to discuss ways to stop counterfeiting and piracy. Interpol has dedicated one officer full-time to work with WHO’s IMPACT program. It has introduced an IP crime training program, beginning in June 2007 and will be expanding these activities.

In 2006 Interpol entered into partnership with the US Chamber of Commerce to develop a database on IP crime to facilitate information sharing. In February 2008, Interpol presented its database on international IP crime (DIIP) at the G8 IP Experts Group meeting in Japan as best practice for all countries to adopt.Critics have raised privacy concerns. Ronald Noble, Interpol’s Secretary General, has stated that “it is no longer acceptable to invoke misguided data-protection arguments for not sharing information.” The politics of fear have facilitated support for a law enforcement approach to IP protection. Interpol and the World Customs Organization enthusiastically have embraced this new mission, with its prospect of high-level support and expanded resources. Thomas Donahue, President and CEO of the U.S. Chamber of Commerce actively has supported an expanded role for Interpol through lobbying government, and targeting “hotbeds” of piracy such as China, India, and Russia. Interpol and the US Chamber of Commerce conducted their 1st Annual Global Forum on Innovation, Creativity and Intellectual Property in Beijing in March 2007, and their 2nd in Mumbai in February 2008. The USCC has provided resources and information for an Interpol Database on International Intellectual Property Crime (DIIP). While Interpol has largely focused on counterfeit pharmaceuticals, it has been working with the Business Software Alliance, the Entertainment Software Association, the International Federation of the Phonographic Industry, and the Motion Picture Association to build internet anti-piracy capacity.

Interpol’s “intellectual property crime” unit fails to provide clear definitions of trademark counterfeiting and copyright piracy; “this is a serious concern for developing countries and consumers, given that the potential scope of the definition of counterfeit and piracy may be so wide as to include legitimate uses of works and cases where an individual may infringe an intellectual property right without knowing it.”

The Security and Prosperity Partnership of North America

The SPP is a White House-led initiative among NAFTA signatories: the US, Canada, and Mexico, “to increase security and to enhance prosperity.” Under a competitiveness rubric the SPP aims to enhance IP enforcement and crack down on counterfeit and pirated goods. It seeks to target export processing zones in particular {maquilladoras}, and has established a task force of senior officials from all three countries to develop a coordinated strategy to combat counterfeiting and piracy. It is best described as an ongoing dialogue rather than a formal agreement or treaty. The US government agencies engaged in this dialogue are the Department of Commerce {“prosperity}, the Department of Homeland Security {security} and the Department of State {to coordinate}. The SPP is focused on increasing private sector engagement in the process to help the North America’s competitive position in the global economy.


In APEC the U.S. has been pressing an “Anti-Counterfeiting Piracy Initiative.” APEC has adopted a number of U.S. proposals including five model guidelines on reducing trade in counterfeiting and pirate goods.

“Think Tanks”

One of the IP maximalists’ objectives is to build a “virtual IP network (NGO) capable of influencing leading European political parties and non-business think tanks in favor of government support for IP – in Germany, Austria, Switzerland, France, Italy, Scandinavia, and the UK.”Industry-supportive “think tanks” have been producing studies for the cause of ratcheting up IP standards and enforcement. For example, industry lobbyist outlets such as the International Intellectual Property Institute, the Institute for Policy Innovation, the Stockholm Network, and the Center for Innovation and Economic Change, have all supplied studies and articles promoting TRIPS-Plus-Plus approaches to IP." (http://www.twnside.org.sg/title2/intellectual_property/development.research/SusanSellfinalversion.pdf)