July 29, 2019
Filed electronically via www.regulations.gov; Docket No. 190703544-9544-01
Earl Comstock
Office of Policy and Strategic Planning Department of Commerce
1401 Constitution Avenue, NW Washington, DC 20230
Re: Comment Request on the State of Counterfeit and Pirated Goods Trafficking and Recommendations, 84 Fed. Reg. 32861, pp. 32861-32863 (July 10, 2019)
Dear Mr. Comstock:
The Entertainment Software Association (“ESA”) welcomes the opportunity to comment on the proliferation of counterfeit goods sold through e-commerce websites. Our response to the Department of Commerce’s (“Department”) request for stakeholder input will also address the industry’s copyright and trademark concerns as well as offer our perspective on potential “best practice” guidance as noted in the Department’s Federal Register notice. The Department seeks perspectives and information on (1) the impact of industry interests affected by counterfeit or pirated goods available on third-party platforms; (2) the factors that contribute to trafficking in these types of goods; (3) the availability of effective technologies that could substantially reduce the sale and importation of counterfeit and pirated goods; (4) the role of collaboration and information-sharing; (5) effective policies, procedures or best practices of private sector stakeholders; and (6) any remedies, including administrative, regulatory, or legislative, to be implemented by the U.S. Government that would substantially reduce the trafficking in illegitimate goods and promote effective law enforcement. ESA intends to address these questions in its filing.
