In September 2020, the DOJ updated its 2015 business review letter to the Institute of Electrical and Electronics Engineers (“IEEE”) standard development organization (“SDO”) that evaluated the IEEE then-imminent revision of its patent policy. The Division undertook this “extraordinary step” in light of an extraordinary and unprecedented set of circumstances, that included systematic misrepresentation and mischaracterization of the Division’s 2015 business review letter (“2015 BR
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