AIPPI 2017 - Study Question - Protection of graphical user interfaces

Study QuestionSubmission date: May 19, 2017

Sarah MATHESON, Reporter GeneralJonathan P. OSHA and Anne Marie VERSCHUUR, Deputy Reporters GeneralYusuke INUI, Ari LAAKKONEN and Ralph NACK, Assistants to the Reporter GeneralProtection of graphical user interfaces

Responsible Reporter: Yusuke INUI

National/Regional Group

Canada

Contributors name(s)

Brian W. Gray, Jean-Charles Grégoire, Fred Barbieri, Curtis Behmann, J. Bradley White, Kevin Carton, Kevin Shipley, Matthew Zischka, Michael Crinson, Patric

k Roszell, Mark Davis

e-Mail contact

cbehmann@blg.com

I. Current law and practice

Patents

1. Can GUIs generally be protected by patents?

If no, please answer questions 1.1, if yes, please go to question 2 YesPlease Explain

In Canada, the patentability of subject matter is assessed based on the essential elements that are identified by purposive construction: Amazon.com, Inc. v. Canada (A.G.), 2011 FCA 328 at paragraph 47. The patent office in Canada takes the position that elements are essential if they are essential to provide a solution to a practical problem to which the claim is addressed: chapter 13.05.03 of the Manual of Patent Office Practice (“MOPOP”); Practice Notice PN2013-02 titled “Examination Practice Respecting Purposive Construction” at pages 2-3 (“PN2013-02”); and Practice Notice PN2013-03 titled “Examination Practice Respecting Computer-Implemented Inventions” at page 5 (“PN2013-03”). See also Patent Office “Refresher training on Purposive construction” (PCon) March 2017.

After purposive construction is performed, patentable subject matter is assessed by determining if the essential elements fall within the definition of invention: div 2 of the Patent Act. While a disembodied idea such as a mere scientific principle or abstract theorem is not patentable, subject matter which has a physical existence or produces a discernible effect or change is patentable: Shell Oil Co. v. Commissioner of Patents, [1982] 2 SCR 536, 1982 CanLII 207 at 554 (S.C.C.); Amazon.com, Inc. v. Canada (A.G.), 2011 FCA 328 at paragraph 66 (“Amazon.com”).

GUIs per se (e.g. an interface of graphical elements) do not generally fall within a statutory category in the definition of invention. However aspects of GUIs can be protected as set out below.

According to the Patent Office, aspects of GUIs can be protected by patents provided a computer (e.g. processor, display or other computer element, or its use) is considered essential to solve the practical problem to which (applying purposive construction) the claim is addressed, In particular, the Patent Office considers that a good indicator that a claim is directed to patentable subject matter is that it provides a technical solution to a technical problem: PN 2013-03 at page 2. In the case where a computer is considered to be an essential element, the claims would fall within the definition of invention.

1.1. If GUIs cannot be protected by patents per se, are any types or aspects of GUIs protectable by patents?

2. If any type or aspect of GUIs are protectable by patents, under what conditions and to what extent are those types or aspects of GUIs considered to be within the scope of patentable subject matter? According to patent office practice, aspects of GUIs can be protected by patents provided a computer is considered essential to provide the solution to the practical problem addressed by the invention.

According to patent office practice, the identification of the problem faced by the inventor is guided by the common general knowledge in the art and by the teachings of the disclosure.

According to patent office practice, use of a computer is not essential where it merely provides the context or the environment of a specific working embodiment. For example, in a review of a rejection of claims to a computer system and a computer readable medium, the Commissioner of Patents has held that the computer system and computer readable medium were not essential, because they did not solve a problem of improving presentation and assimilation of information; they merely provided the operating context. Rather, it was the relative position of objects, their color, size, etc. that solved the problem: Re Application No. 2,295,235 (2016), Commissioner’s Decision No. 1410 at paras. 39, 40.

A consideration is whether the display of information, or printed matter, is functional, as opposed to solely intellectual or aesthetic. For printed matter and the substrate to be patentable subject matter, they must not solve a problem related to the display of the printed matter in general, and must not be based on the solely intellectual or aesthetic significance of the printed matter itself. For example, in a review of a rejection of claims to a method of transmitting a web page from a server to a client computer having a display, the Commissioner has held that the essential elements, to solving a problem of presenting information in an optimal layout, related only to layout (upper graphic region, middle graphic region, lower graphic region). Those essential elements were considered to constitute non-functional printed matter. In contrast, in the same decision, a claim to a computer system for a retail environment was considered patentable, on the basis that a widget bar and its functionality were essential to solving the problem: Re Application No. 2,761,560 (2016), Commissioner’s Decision No. 1411 at paras. 15, 16, 19-25.

3. If yes, do the statutory provisions, case law or judicial or administrative practice require specific claim formats for any patent protection? If yes, what claim formats are available for protecting GUIs?YesPlease Explain

The claims, properly construed, must fall within a statutory category of invention, in particular an art, a process, a machine, or a manufacture: div 2 of the Patent Act. Method, computer readable medium, and apparatus or system claims are commonly used.

The claims must provide a practical application that has a physical existence or that produces a discernable effect or change: Amazon.com at paragraph 66.

4. Is any physical feature required in a claim as a pre-requisite for patentability of a GUI? No

Please Explain

A physical feature per se is not required.

However, a feature that has a physical existence or that produces a discernable effect or change is required as an essential element: Amazon.com at paragraph 66. The Patent Office considers that, where a computer is found to be an essential element, the subject matter will generally be considered patentable: PN2013-03 at page 2.

5. To what extent does involvement of the user's mental activities in a GUI process affect the patentability of the GUI? Mental activities that rely on human judgment are not patentable. However, mental activities that involve the ascertaining and sensing facilities are patentable (provided that one or more of the remaining features has a physical existence or produces a discernable effect or change): Re Application for a Patent Containing Claims that Read on Mental Steps Performed by a Human Operator in Deciding to Transmit a Signal (1972), 23 C.P.R. (2d) 93 at 96 (P.A.B.), followed in Re Application No. 2,203,302 (2004), Commissioner’s Decision No. 1260.

Design rights

6. Can GUIs generally be protected by design rights?

If no, please answer questions 6.1, if yes, please go to question 7 YesPlease Explain

Yes. GUIs, including electronic icons and computer animated designs, which have features of shape, configuration, pattern or ornament that appeal to and are judged solely by the eye, can be protected by industrial design rights in Canada. The Industrial Design Office generally considers GUIs, embodied in a finished article to be registrable. The title must identify the finished article in which the GUI is embodied (e.g. a display screen). The drawings must show the entirety of the finished article in which the GUI is embodied.

6.1. If not, are any types or aspects of GUIs protectable by design rights?

7. If any type or aspect of GUIs are protectable by design rights, under what conditions and to what extent are those types or aspects of GUIs protectable? Yes, a GUI that temporarily appears on a screen of an electronic device is considered, at least by the Industrial Design Office, a "design" that is protectable by design rights.

By way of background, we understand from paragraph 25) of the study question, that a GUI temporarily appears on the screen of an electronic device. Once the device is switched off, the GUI disappears. The study also notes that the traditional approach in Australia has been to draw a distinction between the visual features of a product “at rest" as opposed to "in use".

In Canada, a distinction between the visual features of a product “at rest” as opposed to "in use" has not been clearly drawn. The Industrial Design Act defines an industrial design as “features of shape, configuration, pattern or ornament and any combination of those features that, in a finished article, appeal to and are judged solely by the eye”. An article is defined as

“anything that is made by hand, tool or machine”.

It has been held that a design is to be assessed from the perspective of an informed consumer for originality purposes, in particular its appeal to the eye. An informed consumer appears to contemplate a person who purchases for use and, therefore, a person who assesses the design when the article is purchased or in use. (Consider a jack-in-the-box, which has a clown inside who temporarily appears outside when a crank is turned. An informed purchaser can only assess the appearance of the clown inside in use, when the clown pops out of the box.)

7.a. In particular is a GUI that temporarily appears on a screen of an electronic device considered a "design" that is protectable by design rights? YesPlease Explain

The Industrial Design Office considers electronic icons, including unanimated/animated electronic icons, embodied in a finished article to be registrable. In contrast, the Office does not consider features of an article that do not have a fixed (e.g. in the sense of consistent or unchanging) appearance, for example holograms, to be registrable Accordingly, the Office appears to consider GUIs to be sufficiently fixed or embodied in a finished article, when the article is in use, to be registrable, despite their temporary appearance.

For greater certainty, legislative amendment may be desirable to explicitly ensure that a GUI that temporarily appears on a screen of an electronic device is considered a "design" that is protectable by design rights, or more broadly that designs include visual features of a product in use.

A design application that includes a GUI will be evaluated in the same manner as designs for traditional articles, and the design shall be registered provided it is not identical with or does not so closely resemble any other design already registered as to be confounded therewith.

7.b. In particular is a GUI protectable by design rights independently from the design of the electronic device itself? NoPlease Explain

We understand, from paragraph 26) of the study question, that this question can be related to the characterization of whether the design relates to an aspect of a product "at rest" or "in use". If the assessment only takes account of the product in its unpowered state, it may be only the device itself that is the visual feature.

No, a GUI is not protectable by design rights independently from the design of the electronic device itself. The GUI must be claimed as pattern or ornament for the device on which it appears. However, by including but not “claiming” the device iteself, broad protection can effectively be obtained for the design. In Canada, a design is defined as visual features in or on a device. In the context of GUIs, the Industrial Design Office appears to consider GUIs to be sufficiently embodied in a finished article, when the GUI is displayed on the article in use, to be registrable. To be registrable, the GUI must be displayed or appear in or on an article.

The article can be disclaimed, however. In particular, the features of the electronic device itself can be shown entirely in stippled lines, thereby excluding them from the scope of the design.

7.c. In particular are smaller elements included in a GUI (e.g. icons, slide buttons) protectable by design rights independently from the GUI as a whole? YesPlease Explain

Yes. The GUI and the device it is displayed on should be illustrated in their entirety in the design drawings, but individual portions of the design, including individual icons, buttons, graphics, etc., may be protected independently from the GUI as a whole by showing all other portions of the GUI (and the device it is displayed on) in stippled lines.

7.d. In particular are movements or screen transitions in a GUI protectable by design rights? YesPlease Explain

Yes. The Canadian designs office recently issued a practice notice recognizing computer-generated animated industrial designs as registrable subject matter. The practice notice states that “…applications for computer-generated animated designs are to be examined as a single design applied to a finished article. The drawings submitted with the application will be viewed as a sequence of frames and should sufficiently disclose the animated design for which protection is sought…The individual frames need not include substantially similar content to one another, as they are not assessed independently from their sequential arrangement.”

7.e. In particular are there any other types or aspects of GUIs protectable by design rights? If so, under what conditions and to what extent?YesPlease Explain

Colour may form part of a combination of features of a GUI that constitute a design.

Copyright

8. Can GUIs generally be protected by copyright?

If no, please answer questions 8.1, if yes, please go to question 9 YesPlease Explain

The software code that runs a GUI may be protected by copyright as a literary work. The Canadian Copyright Act provides that a computer program is a literary work and is defined as “a set of instructions or statements, expressed, fixed, embodied, or stored in any manner, that is to be used directly or indirectly in a computer in order to bring about a specific result”.

The visual display of the GUI itself may be protected as an artistic work but Canadian courts are divided on whether a GUI is a reproduction of the software code or is a result of the software code or whether it is a separate independent artistic work. If the GUI is considered to be a reproduction of the software code, or the mere result of the execution of the software code, then the GUI itself would only be protectable by copyright as part of the underlying

computer program. To the extent that the GUI is considered an independent artistic or literary work, the work must be original and the extent to which the author exercised skill and judgement will be a factor in determining whether the GUI has acquired copyright protection. However case law relating to forms, labels and compilations would suggest that the amount of skill and labour involved to qualify for protection is low. In contrast, a GUI which is an entirely functional link to the operation of a computer program, without original artistic expression, will be denied copyright.

8.1. If not, are any types or aspects of GUIs protectable by copyright?

9. Does the fact that GUIs shown on screens are computer-generated affect the eligibility of GUIs for copyright protection? NoPlease Explain

The Canadian Copyright Act provides that a computer program is a literary work as it is “a set of instructions or statements, expressed, fixed, embodied, or stored in any manner, that is to be used directly or indirectly in a computer in order to bring about a specific result”.

If the GUI is considered to be a mere result of the execution of the software code, then the GUI itself would not be protectable by itself apart from the underlying computer program that created it.

There must be sufficient exercise of skill and judgement by the author of the GUI display to be protectable by copyright. The exercise of skill and judgment required to produce the work must not be so trivial that it could be characterized as a purely mechanical exercise. For example, any skill and judgment that might be involved in simply changing the font of a work to produce "another" work would be too trivial to merit copyright protection as an "original" work.

However the fact that the GUI appears on the screen only during the operation of the device would not disqualify the artistic work for protection.

10. If any type or aspect of GUIs can be protected by copyright, under what conditions and to what extent are those types or aspects of GUIs protectable?See the answer to question 8 above. Copyright protects only the original artistic expression and not any underlying ideas. However to the extent that the artistic expression may be created on screen by an number of different underlying computer programs, it is likely that the created artistic expression should still be protected as such.

11. Can the overall "look and feel" of GUIs be protected by copyright?

If no, please answer questions 11.1, if yes, please go to question 12 YesPlease Explain

There is insufficient case law in Canada with respect to GUIs and copyright.

The overall “look and feel” of a GUI may arguably be considered as an artistic work if the visual aspects are sufficiently original and not functional. However such protection does not prevent copying of the underlying functionality or functional structure implemented by the

interface. If the content and layout of the GUI is largely dictated by utilitarian features or technical requirements, it does not qualify for copyright protection.

Individual artistic or literary elements that are separable from the GUI may be protectable by copyright if they are original, and if they can be considered as artistic works in and of themselves.

11.1. If not, can individual elements included in a GUI be protected?

Trademarks

12. Can GUIs generally be protected as trademarks?

If no, please answer questions 12.1, if yes, please go to question 13YesPlease Explain

Any word, design, logo, figurative element or moving image, can function as a trademark provided it is used to distinguish goods or services and is therefore recognized as an indication of the source of goods and services.

Canadian trademark rights arise from use – registration is not required. However given that GUIs by definition function to provide an interface between the user of a computer program and the program itself, there may be difficulties in establishing that the GUI is itself acting as a source identifier and not as a functional (albeit aesthetically pleasing) interface with the program itself. However it would still seem possible that, by consistent use of a GUI to identify a brand and by proper messaging, a GUI would be seen by a user as an indication of the source or brand for the digital service or program with which the user is interacting.

12.1. If not, are any types or aspects of GUIs protectable by trademarks?

13. If any type or aspect of GUIs are protectable as trademarks, under what conditions and to what extent can those types or aspects of GUIs protectable? Please see the answer to question 13.1.

13.1. For example, is a screen movement or transition in a GUI protectable as a trademark? YesPlease Explain

Provided that the screen movement or transition is being used as a trademark (i.e. to distinguish the goods or services being provided), it is registrable and protectable as a trademark. If the screen movement is functional it would seem generally that such movement would not be seen to have brand or source significance and therefore not be functioning or protectable as a trademark.

14. Does a GUI need to acquire secondary meaning through use in order to be

protected as a trademark? NoPlease Explain

A GUI which is an inherently distinctive element (i.e. not descriptive) does not need to acquire secondary meaning through use in order to be protected as a trademark provided is used by a person for the purpose of distinguishing or so as to distinguish their goods or services from those of others. However a GUI which appears functional or which is descriptive or not distinctive for other reasons, may need to acquire a secondary meaning to be protected. Of course all trademark protection is strengthened by use and the scope and nature of that protection is thereby enlarged.

Other forms of protection

15. Does your Group's current law provide any other means for protecting GUIs that are similar in nature to traditional IP rights? YesPlease Explain

Yes the look and feel of a computer program may be protected by common law rights to prevent deception or misleading representations such as by an action for passing off in respect of the trade dress, look and feel or other aspects of appearance that might lead to confusion as to source or origin.

16. If yes, what forms of protection are available, and under what conditions, and to what extent, are such other forms of protection available?See the answer to 15 above.

II. Policy considerations and proposals for improvements of your Group's current law17. Does your law provide sufficient IP rights protection for GUIs? If yes, is that by means of any one or more types of IP rights protection (and if so, which), or by means of combination of those types of IP rights protection?

If no, please answer questions 18, if yes, please go to question 19 YesPlease Explain

Yes there is sufficient protection, but clarification is required in the following areas: 1. Patents: it would be helpful to better define when a GUI represents a structure that produces a discernable effect or change that is essential to the invention as claimed. This is a subset of the general uncertainty surrounding whether or when a computer is an essential feature of the practical problem addressed by the claim. 2. Design. Clarification is desirable concerning the extent to which the protection for a design applied to an article, which is not claimed as part of the design, is restricted to the application of that design on that article only. 3. Clarification is desirable as to whether a GUI which is an artistic or literary work produced by a computer program is protectable as a stand-a-lone artistic or literary works apart from the underlying computer program. 4. Trademarks: clarification is desirable as to when the GUI is

merely serving as a functional part of the operation of an interface or rather functioning as a brand.

18. If no, how is your law deficient?

19. Is your law sufficiently clear on whether and to what extent GUIs are protected by various IP rights?

If no, please answer questions 20, if yes, please go to question 21 NoPlease Explain

See answer to 17 above.

20. If no, how is your law deficient in this regard?See answer to number 17 above.

21. Are there any aspects of your law that could be improved (for example, by strengthening or reducing the extent to which GUIs may be protected)?YesPlease Explain

See answer to number 17 above.

III. Proposals for harmonisation22. Does your Group consider that harmonisation in this area is desirable? If yes, please respond to the following questions without regard to your Group's current law. Even if no, please address the following questions to the extent your Group considers your Group's laws could be improved. YesPlease Explain

Please see answers to individual questions below.

Patents

23. Should GUIs generally be capable of protection by patents?

If no, please answer questions 23.1, if yes, please go to question 23.2 YesPlease Explain

There is no need for GUIs per se to be capable of protection by patents, at least in Canada.

GUIs which are novel and inventive and implemented by technical or computer means which are essential to the solution of the problem addressed by the invention should be protectable by patents. Patent should be one of the ways to protect GUIs where the appropriate technical elements are present.

23.1. If not, should at least some types or aspects of GUIs be protectable by patents?

23.2. Please explain your reasons.Please see answer to question 23 above.

24. Under what conditions, and to what extent, should GUIs fall within the scope of patentable subject matter? Mental activities that rely on human judgment should not be patentable, but mental activities that involve the ascertaining and sensing facilities should patentable.

24.1. For example, should involvement of user's mental activities in a GUI process affect the patentability of the GUI?

24.2. Please explain your reasons.Please see answer to question 24 above.

25. Should a physical feature be required in a claim as a pre-requisite for patentability of GUIs? NoPlease explain your reasons

No, a physical feature per se should not be required in a claim as a pre-requisite for patentability of GUIs. However, the claim should provide a practical application that has a physical existence or that produces a discernable effect or change.

26. What claim formats should be available for protecting GUIs?Claim formats available for protecting GUIs should include at least method, computer readable medium, and apparatus or system claims.

Design rights

27. Should GUIs generally be capable of protection by design rights?

If no, please answer questions 27.1, if yes, please go to question 27.2 YesPlease Explain

Yes, GUIs which have features of shape, configuration, pattern or ornament that appeal to

and are judged solely by the eye should generally be capable of protection by design rights, providing certainty to both registrants and subsequent users of similar subject matter. GUIs which are dictated solely by a utilitarian function should not be registrable as designs. We also believe that portions or sub-components of GUIs should be protectable by design rights, in addition to the entire GUI also being protectable.

The foregoing does not preclude patent, copyright or trade-mark right acquisition, as there is no reason to exclude complementary protection simply because of design protection.

27.1. If not, should at least some types or aspects of GUIs be protectable by design rights?

27.2. Please explain your reasons.See answer to question 27 above.

28. Under what conditions, and to what extent, should GUIs be protectable by design rights? Canada presently provides protection for appearance only via design rights. The conditions include claiming the display or device on which the GUI is provided, for example by describing the article as a “display” rather than a GUI. New guidelines issued in January of this year confirm that design protection is available for animated designs, which include screen movements or transitions in a GUI.

28.1. For example, should screen movements or transitions in a GUI be protectable by design rights? YesPlease explain your reasons.

See answer to question 28 above.

29. Should a GUI be protectable by design rights independently from the design of the electronic device itself? YesPlease explain your reasons.

A GUI like all designs must be applied to a finished article and protected in the context of a finished article. Current GUI protection by design rights in association with an electronic device provides effective protection in most scenarios. Current practice allows a GUI to be protected in connection with the context of a display screen or device in which the screen or device itself is not claimed and does not form part of the design. However case law is unclear as to the extent to which such context limits the scope of the design. Clarification of the scope of protection in respect of designs applied to unclaimed portions of an article would be beneficial. For example, there can be a large variety of devices and displays on which the GUI could be displayed, without changing the character of the GUI. Also, protection of a GUI that is tied to the display or electronic device itself may not sufficiently cover implementations in virtual reality, augmented reality, or similar future technologies in which the GUI may not be displayed on a finished article, but rather by some means of projection.

Protection of a GUI independent of the electronic device or display would require a change in

practice in Canada, which currently requires that the design be directed to the finished article to which the design is applied.

Copyright

30. Should GUIs generally be capable of protection by copyright?

If no, please answer questions 30.1, if yes, please go to question 30.2 YesPlease Explain

Yes original artistic and literary works should be protected by copyright regardless of whether they are created by a computer program and independent of the computer program and without regard to the mode or medium of expression.

30.1. If not, should at least some types or aspects of GUIs be protectable by copyright?

30.2. Please explain your reasons.See answer to question 30 above.

31. Should the fact that GUIs shown on screens are computer-generated affect the eligibility of GUIs for copyright protection? NoPlease explain your reasons.

No, difficulties of determining authorship should not bar copyright protection. The GUI is created by the persons who authored the computer program. The medium of expression should not be bar as long as the GUI is sufficiently fixed in some tangible form and identifiable.

32. Under what conditions, and to what extent, should GUIs protectable by copyright? Any literary, dramatic, artistic or musical work which is original, aesthetic, arbitrary, not functional, which involves the skill and judgment of the author and which forms part of the “look and feel” of the digital work should be protected just as any other copyrightable work.

32.1. For example, should the overall "look and feel" of a GUI be protectable by copyright? YesPlease explain your reasons.

See answer to question 32 above.

Trademarks

33. Should GUIs generally be capable of protection as trademarks?

If no, please answer questions 33.1, if yes, please go to question 33.2 YesPlease Explain

GUIs are generally capable of protection as trademarks provided they are used for the purpose of distinguishing or so as to distinguish their goods or services from those of others. Accordingly, an icon used as the initial interface for an application might be protectable as a trademark, but a GUI appearing internally as part of the user interaction with the program or that it is used in the operation of the program to perform a function is unlikely to be acting as a source identifier and therefore will not be and should not be protectable as a trademark.

33.1. If not, should at least some types or aspects of GUIs be protectable as trademarks?

33.2. Please explain your reasonsSee answer to question 33 above.

34. Under what conditions, and to what extent, should GUIs be protectable as trademarks? See answers below.

34.a. For example should screen movements or transitions in a GUI be protectable as trademarks? YesPlease Explain

Screen movements or transitions in a GUI that are used for the purpose of distinguishing or so as to distinguish goods or services from those of others, and are understood by others as performing that function, are protectable as trademarks in Canada. However it is likely that where the GUI is preforming a function in connection with some selection, movement or transition that in that case it is not performing a trademark function and therefore not protectable as a trademark.

34.b. For example should a GUI be required to acquire secondary meaning through use, in order to be protected as a trademark?NoPlease Explain

A GUI should not be treated differently from any other trademark if it is operating as a source identifier. If the mark is arbitrary and not descriptive, it does not have to acquire secondary meaning through use in order to be protectable. See the answer to question 14. However, a GUI that has been registered as a trademark but that is not distinctive is subject to challenge and cancellation.

Other forms of protection

35. Should there by other forms of protection for GUIs? If so, what forms of protection should there be?NoPlease explain your reasons

Other forms are not necessary as long as there also basic rights (such as by passing off or trade dress protection) to prevent the use of GUIs to deceive the user.

36. Should there be a sui generis right for protection of GUIs? If so, what aspects of GUIs should be protected by such a right, to what extent, and under what conditions?

If yes, please answer questions 37, if no, please go to question 38 NoPlease Explain

There is no need for a sui generis right.

37. Should there be any exceptions or limitations to a sui generis right in order to ensure an innovative and competitive market? If so, what exceptions and limitations should there be and why?

38. Please comment on any additional issues concerning protection of GUIs that your Group considers relevant to this Study Question

Please indicate which industry sector views are included in part "III. Proposals of harmonization" on this form:

Please enter the name of your nominee for Study Committee representative for this Question (see Rule 12.8, Regulations of AIPPI). Study Committee leadership is chosen from amongst the nominated Study Committee representatives. Thus, persons not nominated as a Study Committee representative cannot be in the Study Committee leadership.

Brian Gray