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9.

The bill (sec. 2, p. 3, lines 3-6) selectively permits the term
"copy" to apply to chips only under a limited number of
sections of the Copyright Act (and presumably no others)
where that term now appears. Such legislation would add a
gray third category to what is otherwise a reasonably clear
division of tangible fixations of works into only two categories
throughout the entire Act: "copies" and "phonorecords."

10.

Computer programs and data bases often reside in chips. The

bill may inadvertently sweep into its compulsory licensing
scheme these copyrighted works.

11.

The copyright term under the bill would be computed
differently from that of all other works under the Copyright
Act as well as being of a different duration. The creation of
such new concepts and provisions as part of a very traditional
body of law must be given very careful consideration.

It appears to ADAPSO that the above points raise a substantial question whether the agreed upon need for protection of semiconductor chips is best served through a proposed amendment of the Copyright Act. We believe that additional consideration must be given this question before specific refinements of the language of the proposed legislation are addressed.

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Bar Association of the City of New York

- Member, Computer Law Committee

Subcommittee Chairman, Software Protection Committee

Industry

Association of Data Processing Organizations

Former Chairman, International Committee

Chairman, Vendor Relations Committee

Member of Board of Directors, Software Products Section and
Professional Services Section

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Keynote Speaker, Japanese Software Industry Association Meeting 1980.

Speaker, Practicing Law Institute Conference on Computer Law

Co-Chairman, United States, for First International Meeting for Data Processing Orgaanizations Barcelona, 1978.

Seminar Chairman, Legal aspects of Computer License Agreements Barcelona, 1978.

COOPERATIVE
RESEARCH

SEMICONDUCTOR RESEARCH CORPORATION

October 31, 1983

The Honorable Robert W. Kastenmeier
Chairman

Subcommittee on Courts, Civil Liberties

and the Administration of Justice 2137 Rayburn House Office Building Washington, DC 20515

Dear Congressman Kastenmeier:

Your subcommittee is currently considering the Semiconductor Chip Protection Act of 1983 (H.R. 1028) sponsored by Rep. Don Edwards. I write on behalf of the Semiconductor Research Corporation to express our appreciation of your efforts to hold hearings on this bill and to urge you to support this essential legislation and move it on to speedy enactment.

One of the major goals of the cooperative research currently sponsored by SIA member companies through the Semiconductor Research Corporation is the capability to automatically design semiconductor chips that represent the integration of literally millions of transistors onto a "chip" of silicon that is wafer-thin and about one quarter of an inch square. Manually, this task represents hundreds of thousands of man hours which is prohibitively expensive. The investment in research to automate the design process is negated if copyright protection is not granted under the law.

As a formal statement of our position, we ask that this letter be entered into the record of your hearings on H.R 1028

Sincerely

Larry W. Suney

Executive Director

LWS:mpr

CC: Rep. Ed Zschau

Rep. Don Edwards

300 PARK DRIVE, SUITE 215 • P.O. BOX 12053 • RESEARCH TRIANGLE PARK NC 27709⚫ (919) 549-9333

American Electronics Association

Government Operations Office

1612 K Street N W

Washington DC 2,306

(202,33 8050

November 1, 1983

AEA

The Honorable Robert Kastenmeier
Chairman

Subcommittee on Courts, Civil Liberties and the
Administration of Justice

Room B-2137, Rayburn House Office Building
Washington, D.C. 20515

Dear Chairman Kastenmeier:

AEA

The American Electronics Association (AEA) supports the passage of H.R.1028, the Semiconductor Chip Protection Act of 1983. represents over 2,300 member companies nationwide, and over 450 financial, legal and accounting organizations which participate as associate members. AEA companies account for 63 percent of the worldwide sales of U.S. based electronics companies. Approximately 72 percent of AEA companies are small businesses employing fewer than 200 people; and twelve percent are large companies employing more than 1000 people.

For the electronics industry to remain competitive, it is imperative that semiconductor designers have legal protection from pirate firms that copy their designs. H.R.1028 would give semiconductors designers the protection necessary to continue the innovative progress that has contributed to the success of our industry.

Passage of H. R. 1028 is particularly important at a time when new generations of semiconductor products will soon enter the market. Semiconductors must have legal protections as soon as possible if America is to keep its edge in the electronics field.

AEA encourages your subcommittee to hold additional hearings on this legislation so that it can be further discussed and hopefully be passed as expeditiously as possible.

Sincerely yours,

Kenneth C.0. Hagerty
Vice President,

Government Operations

GENERAL ELECTRIC

SEMICONDUCTOR BUSINESS DIVISION

GENERAL ELECTRIC COMPANY ONE MICRON DRIVE RESEARCH TRIANGLE PARK, NC 27709 ● (919) 549-3100

October 20, 1983

The Honorable Robert W. Kastenmeier
Chairman

Subcommittee on Courts, Civil Liberties
and the Administration of Justice
2137 Rayburn House Office Building
Washington, D.C. 20515

Dear Mr. Kastenmeier:

The General Electric Company appreciates your Subcommittee's consideration of H.R. 1028, the Semiconductor Chip Protection Act of 1983, and would like to add our support of the bill to the record of the hearings you have chaired.

This bill is one which is particularly important at a time when a new generation of semiconductor products will soon enter the market. If these new chips are copied, it will cost the U.S. industry tens of millions of dollars per year and will certainly deter future innovation.

We hope you will support H. R. 1028. With your support, the bill can soon begin to provide protection to firms in our industry.

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