SBTC submitted a comment in response to an Advanced Notice of Proposed Rulemaking concerning a change in the SBIR/STTR data rights. In 2019, new SBIR/STTR policy directives were issued requiring offices to grant SBIR/STTR contracts a 20-year data rights protection period. The new proposed rule would formalize and promulgate this protection period at the DOD. SBTC strongly supports this new data rights protection period, but it is important to make sure the language is clear and precise to ensure that while the protection period is extended, it is not weakened in other ways.
SBTC’s comment proposes language clarification for several passages that are unclear, and deletion of a few requirements that would be unnecessarily onerous and burdensome for small businesses. It is separated into two parts: an Appendix A which offers summary and rationale for all proposed edits, and an Appendix B, which transposes SBTC’s suggested changes into the full DFARS proposed rule.
Please follow the link below to view SBTC’s comment:
Comment on DOD SBIR Data Rights (DFARS Case 2019-D043)