The story of Standard Essential Patents in India is, at its core, a story about two competing ideas: the right of an inventor to profit from a technology that the entire world has come to depend on and the right of every device manufacturer, service provider and ultimately every consumer to access that technology on terms that do not suffocate competition. When a technology becomes so central to an industry standard think the codec that compresses every voice call on a 2G or 3G network or the protocol that allows a device to connect to a wireless network at all the patent covering it ceases to be an ordinary property right. It becomes something closer to infrastructure. The owner of that patent sits at a tollbooth on a road that everyone must use and the question of what toll is fair has generated some of the most commercially consequential and intellectually demanding litigation that Indian courts have seen in a generation.
India arrived relatively late to this conversation by global standards. The United States, the European Union and several Asian jurisdictions had been grappling with Standard Essential Patent (SEP) licensing disputes since the early 2000s. But when the disputes arrived in India, they arrived with particular intensity, because India’s telecommunications market one of the world’s largest by subscriber count had by the 2010s become home to dozens of domestic handset manufacturers who were building affordable mobile devices for hundreds of millions of users and doing so without formal patent licences from the global technology companies whose innovations sat inside every chipset. What followed was a wave of litigation before the Delhi High Court, parallel proceedings before the Competition Commission of India (CCI) and a series of judgments that have, over the course of a decade, built a body of Indian SEP jurisprudence that is now closely studied internationally. This article explains what SEPs are, how the FRAND commitment works, what Indian law currently says about both and what the most important cases tell practitioners and applicants about how to navigate this terrain.
What is a Standard Essential Patent and Why Does It Matter
A Standard Essential Patent is a patent that covers technology which is indispensable to implementing a technical standard. The key word is “essential”: the implementer of the standard anyone manufacturing a device or providing a service that conforms to the standard cannot avoid using the patented technology. There is no workaround, no design-around, no alternative. Either you implement the patented technology or you do not implement the standard.
Standards are developed by Standards Setting Organisations (SSOs), sometimes also called Standards Development Organisations (SDOs). In telecommunications, the most consequential of these is the European Telecommunications Standards Institute (ETSI), which has developed the GSM, UMTS (3G), LTE (4G) and NR (5G) standards that govern mobile communications globally. Other SSOs of importance include the Institute of Electrical and Electronics Engineers (IEEE), which governs Wi-Fi standards and the International Telecommunication Union (ITU). SSOs require their members technology companies, equipment manufacturers, research organisations to disclose patents that may be essential to a standard being developed and to commit, as a condition of participation, that they will license those patents to implementers on Fair, Reasonable and Non-Discriminatory (FRAND) terms. This commitment is typically made through an intellectual property rights policy, the ETSI IPR Policy being the most widely referenced.
The logic of the FRAND commitment is straightforward. Without it, a patent holder whose technology was incorporated into a standard would enjoy enormous leverage a private veto over every implementation of the standard worldwide. The FRAND commitment is the price that the SSO extracts in exchange for elevating the technology to standard status and it is meant to ensure that the resulting monopoly position is not weaponised to extract excessive royalties or discriminate among licensees.
What the FRAND commitment does not do is define with mathematical precision what a fair, reasonable and non-discriminatory royalty rate actually is. That question the core dispute in virtually every SEP case anywhere in the world is left to negotiation between the SEP holder and the implementer, and, when negotiation fails, to courts or arbitrators. And negotiation fails frequently, because the financial stakes are enormous: a portfolio of hundreds or thousands of SEPs licensed at even a fraction of a percentage of device revenues, across millions of devices, generates billions of rupees in royalties.
The Statutory Landscape: SEPs Under the Patents Act, 1970
The Patents Act, 1970, as it currently stands, does not contain a definition of Standard Essential Patents or any specific provision governing FRAND licensing. This absence is not unusual most patent statutes worldwide predate the SEP problem and do not address it explicitly. What the Act does provide, across several of its provisions, is a framework that Indian courts have used to address SEP disputes through existing legal tools.
Section 48 of the Patents Act, 1970 confers on the patentee the exclusive right to prevent third parties from making, using, offering for sale, selling or importing the patented product in India without the patentee’s consent. This right applies to SEPs as it does to any other patent a fact that has been confirmed repeatedly by the Delhi High Court, which has rejected arguments that a FRAND commitment somehow waives or diminishes the patentee’s right to seek injunctive relief for infringement.
Section 84 of the Act, governing compulsory licensing, is relevant because one of its three grounds for grant is that the patented invention is not available to the public at a reasonably affordable price. An SEP holder who charges supra-FRAND royalties and thereby makes standard-compliant products unaffordable could, in principle, face a compulsory licensing application on this ground. Section 84 has not, to date, been applied in a pure SEP context the only compulsory licence granted in India, in the Nexavar case discussed later, arose from a pharmaceutical patent but its shadow falls over every SEP negotiation in India and operates as a background constraint on royalty demands.
Section 90 of the Act, which governs the terms and conditions of compulsory licences, requires that licences not be unduly restrictive and that royalties be reasonable. Section 140, which renders certain restrictive conditions in patent licences void, has potential relevance to SEP licensing in prohibiting conditions that tie a licensee to the licensor’s other products or restrict competition in ways not reasonably necessary for the protection of the patent. And Section 89, which sets out the general purposes for granting compulsory licences, includes the working of the patented invention in India to the fullest extent, the availability of the patented article at reasonably affordable prices and the balancing of the patentee’s interests with public interest all of which resonate directly with the FRAND framework.
The Royalty Base Debate: Smallest Saleable Patent Practising Unit or End-Device Price
Before turning to the major cases, it is necessary to understand the single most contentious technical question in SEP royalty disputes, because it runs through virtually every Indian judgment on the subject. When a FRAND royalty is expressed as a percentage, the question is: a percentage of what?
The SEP holder typically prefers to calculate royalty on the net selling price of the final product the mobile phone, the tablet, the connected vehicle. The implementer typically argues that the royalty should be calculated on the value of the smallest saleable patent practising unit (SSPPU) the chipset, the modem or the individual component that actually implements the standard. The difference is enormous in monetary terms: a mobile phone that sells for rupees fifteen thousand contains a 4G modem that might cost a fraction of that amount, so a royalty of one percent on the end-device price is many times larger than the same percentage applied to the modem.
The SSPPU argument has found support in some US jurisprudence, particularly in the reasoning of certain district courts and is endorsed by some economists and competition regulators. The comparable licence approach looking at what rates other implementers have paid for similar portfolios under similar circumstances is more widely accepted globally, including at the UK Supreme Court and before some German courts. Indian courts have, as we shall see, engaged substantively with both approaches and have generally rejected the SSPPU argument in the context of portfolio licensing, while endorsing the comparable licence methodology as the primary tool for FRAND rate determination.
Telefonaktiebolaget LM Ericsson v. Micromax Informatics Ltd.: The Opening Battle
The wave of SEP litigation in India began in earnest when Ericsson, the Swedish telecommunications giant that holds one of the world’s largest portfolios of 2G, 3G and 4G SEPs, approached multiple Indian handset manufacturers seeking to negotiate FRAND licences. When negotiations collapsed, Ericsson turned to the Delhi High Court. Among the first of these battles was the dispute with Telefonaktiebolaget LM Ericsson v. Micromax Informatics Ltd. (Delhi High Court, CS(OS) No. 442/2013), which commenced in 2013.
Micromax was, at the time, one of India’s largest handset manufacturers by volume, producing affordable Android devices for the mass market. Ericsson alleged infringement of its SEPs relating to GSM, GPRS, EDGE and 3G technologies, all of which were essential to standards that every 2G and 3G-compliant phone necessarily implements. The Delhi High Court granted interim relief in Ericsson’s favour, directing Micromax to pay interim royalties into court pending the determination of FRAND rates. The court found on a prima facie basis that the Ericsson patents were valid and essential and that Micromax had been using the patented technology without a licence despite being approached for one. The interim order in this case directing payment of royalties on the net selling price of end-devices set an important early precedent on the royalty base question, establishing that the end-device price rather than the chipset price was the appropriate starting point for the calculation.
Micromax responded by filing a complaint before the Competition Commission of India under Section 19(1)(a) of the Competition Act, 2002, alleging that Ericsson had abused its dominant position by demanding exorbitant and discriminatory royalties. This initiated a parallel track of proceedings that would eventually lead to one of the most significant jurisdictional rulings in Indian IP law.
Telefonaktiebolaget LM Ericsson v. Intex Technologies (India) Ltd.: Laying the Foundations
The dispute between Ericsson and Intex Technologies is the most doctrinally significant of the early Indian SEP cases, both at the interim stage and on appeal. In Telefonaktiebolaget LM Ericsson (PUBL) v. Intex Technologies (India) Limited, CS(OS) No. 1045/2014, Ericsson filed suit in April 2014 alleging infringement of eight SEPs relating to 2G and 3G technologies. The Single Judge of the Delhi High Court, in an order dated March 13, 2015, found that Ericsson’s suit patents were prima facie valid and essential, that Intex had prima facie infringed them and that Ericsson had complied with its FRAND commitment. Critically, the court also found that Intex’s conduct prolonging pre-suit negotiations and then approaching the CCI and IPAB in the midst of those negotiations constituted prima facie evidence of its unwillingness to take a FRAND licence. The court directed Intex to pay a royalty on end-device net selling price and rejected the argument that the chipset basis for calculating royalty was appropriate.
The appeal by Intex and Ericsson’s cross-appeal against this order came to be decided by a Division Bench of the Delhi High Court in a judgment dated March 29, 2023, in FAO (OS) (COMM) 296/2018 and 297/2018. This judgment is, as of the time of writing, the most comprehensive and carefully reasoned statement of Indian SEP law at the appellate level below the Supreme Court. The Division Bench affirmed the Single Judge’s conclusions on prima facie validity, essentiality and infringement and directed Intex to pay the full royalty amount rather than the split arrangement of fifty percent upfront and fifty percent by bank guarantee that the Single Judge had ordered. More importantly for the development of Indian law, the Division Bench extensively surveyed SEP jurisprudence from the United Kingdom, the United States, Germany, China and other jurisdictions, synthesised it with Indian legal principles under the Patents Act, 1970 and produced a set of guidelines for how SEP licensing negotiations should be conducted and how courts should approach interim relief in SEP disputes. The court held that an unwilling licensee one that delays negotiations, makes no genuine counter-offers or runs parallel proceedings before competition authorities as a litigation tactic is not entitled to the equitable protection that courts extend to good-faith implementers who are genuinely engaged in FRAND negotiations.
The Jurisdictional War: Patents Act vs. Competition Act
The CCI complaints filed by Micromax, Intex and iBall against Ericsson set the stage for a long-running jurisdictional dispute that was resolved at least at the Delhi High Court level in 2023 and is currently pending before the Supreme Court.
In Telefonaktiebolaget LM Ericsson (PUBL) v. Competition Commission of India, 2023 SCC OnLine Del 4078, a Division Bench of the Delhi High Court, consisting of Justice Najmi Waziri and Justice Vikas Mahajan, delivered a judgment on July 13, 2023, that disposed of four appeals and a writ petition arising out of the CCI’s decisions directing investigation against Ericsson based on the Micromax and Intex complaints. Ericsson contended that the Patents Act, 1970, as a special law comprehensively governing all aspects of patent rights including licensing, must prevail over the Competition Act, 2002, a general law of market regulation. The court agreed. Applying the twin maxims of statutory interpretation generalia specialibus non derogant (general provisions do not override special provisions) and lex posterior derogat priori (a later law prevails over an earlier one) the court held that Chapter XVI of the Patents Act, 1970, which deals with compulsory licensing, working of patents and related matters including licensing terms and abuse of patentee status, constitutes a complete code in itself and is a subsequent legislation enacted after the Competition Act. The Patents Act must therefore prevail over the Competition Act in matters involving the exercise of rights by a patentee in respect of the patented technology. The CCI was held to lack jurisdiction to investigate Ericsson’s SEP licensing conduct.
This judgment was challenged by the CCI before the Supreme Court of India, which on March 1, 2024, issued notices to Ericsson and Monsanto in response to the special leave petition filed by CCI. The Supreme Court’s eventual ruling on whether the Patents Act or the Competition Act governs SEP licensing disputes will be the single most consequential legal event in Indian IP law in many years. The answer will determine whether India takes a patent-centric approach to SEP regulation with the Controller of Patents as the primary authority or a competition-law approach that gives the CCI concurrent or primary jurisdiction to adjudicate claims of royalty abuse and discriminatory licensing. As things stand, the Delhi High Court’s ruling means that the Patents Act framework governs and the CCI has no jurisdiction, but this position is subject to Supreme Court review.
Lava International Ltd. v. Telefonaktiebolaget LM Ericsson: India’s First Final SEP Judgment The most significant SEP judgment that Indian courts have produced is the final decision in Lava International Ltd. v. Telefonaktiebolaget LM Ericsson, 2024 SCC OnLine Del 2497, delivered by the Delhi High Court on March 28, 2024. This was the first time an Indian court concluded a full trial in an SEP case and arrived at a final determination on essentiality, infringement, FRAND royalty rates and damages.
The facts of the case trace back to November 2011, when Ericsson first approached Lava India’s third-largest smartphone manufacturer by market share seeking to negotiate a FRAND licence for its portfolio of 2G and 3G SEPs. Negotiations continued for over three years without agreement. Lava filed a suit before the District Court of Noida seeking a declaration that Ericsson had waived its rights to enforce its SEPs by not asserting them against chipset manufacturers or against device manufacturers in China and seeking a court-determined FRAND rate. Ericsson responded by filing suit before the Delhi High Court in 2015, claiming infringement of eight of its SEPs relating to EDGE, 2G and 3G technologies, seeking a permanent injunction and damages and seeking a declaration that its offered rates were FRAND. The Supreme Court transferred the Noida suit to the Delhi High Court in July 2015 for consolidation. An interim conditional injunction was granted against Lava, which was directed to deposit rupees thirty crore with the court.
Trial commenced in February 2016 and concluded in July 2016, with final hearings running from February 2023 to May 2023. The court, in a judgment running to 476 pages, found that seven of Ericsson’s eight asserted SEPs were valid and essential and that Lava had infringed them all. Lava’s counterclaim for revocation of Ericsson’s patents, including challenges under Section 3(k) of the Patents Act, 1970, was dismissed. The court determined the FRAND royalty rate applicable to Lava at 1.05% of the net selling price of Lava’s devices, applying the comparable licensing approach looking at what rates similarly placed entities had agreed to pay Ericsson under comparable circumstances and awarding damages of rupees 244 crore (approximately USD 29 million) with interest at five percent from the date of judgment. This is the largest patent damages award in Indian litigation history and it represents a definitive statement that India takes SEP enforcement seriously and will not permit implementers to use the technology of patent holders without agreeing on FRAND terms.
Lava appealed the judgment to a Division Bench of the Delhi High Court in May 2024. The appeal is pending and Lava failed to obtain a stay on the damages order, though an interim deposit arrangement was put in place. The outcome of the appeal will determine whether the doctrinal framework established in the March 2024 judgment particularly on essentiality determination methodology, the comparable licensing approach to FRAND rate-setting and the Section 3(k) analysis of telecommunications protocol patents becomes settled Indian law.
The Comparable Licensing Approach and Its Implications for Rate-Setting
The Delhi High Court’s endorsement in the Lava judgment of the comparable licensing approach as the primary method for determining FRAND royalty rates deserves specific attention, because it has immediate practical implications for every SEP negotiation conducted in India.
The comparable licensing approach requires the court to look at licences that the SEP holder has executed with other implementers in comparable circumstances similar technology, similar level in the supply chain, similar geographic scope, similar time period and use the rates in those licences as a benchmark for what a FRAND rate should be. The court in the Lava case found that Ericsson’s offered rates to Lava were substantially identical to rates offered to other similarly situated Indian handset manufacturers, which the court treated as strong evidence of non-discrimination. Critically, the court rejected the top-down approach in which the aggregate royalty burden for the entire standard is first estimated and then apportioned proportionally to the asserted portfolio as less reliable in the Indian context where comprehensive data on all patents essential to a given standard is not readily available.
The court also addressed the royalty base question and, consistent with the earlier Single Judge decisions in the Micromax and Intex disputes, applied the net selling price of the end-device rather than the SSPPU as the royalty base. The court reasoned that portfolio licensing at the end-device level reflects how the telecommunications industry has historically operated and that the value of the patented technology is better reflected in the price of the product that the consumer purchases, which is the device that uses the standard to make calls, connect to networks and access services.
Hold-Up, Hold-Out and What Indian Courts Have Said About Negotiating Behaviour
A recurring theme in the global SEP debate is the twin problem of hold-up and hold-out. Patent hold-up describes the situation where an SEP holder extracts royalties greater than the competitive value of its technology, exploiting the fact that the implementer has already committed to the standard and cannot easily switch to an alternative. Patent hold-out or reverse hold-up, describes the situation where a large or well-resourced implementer deliberately delays licensing negotiations, uses litigation and regulatory proceedings as leverage to drive down royalty rates and effectively uses the patented technology without paying for it for as long as the legal process allows.
Indian courts have demonstrated awareness of both phenomena and have addressed them in the context of interim relief. The Division Bench in the Intex appeal noted that an implementer who approaches the CCI or the IPAB as a litigation tactic while negotiations are ongoing, without making any genuine counter-offer, is demonstrating unwillingness to take a FRAND licence and is not entitled to the equitable protection that courts extend to good-faith negotiators. This is a significant principle: it means that filing a CCI complaint during ongoing FRAND negotiations a strategy that several Indian manufacturers employed in the early phase of the Ericsson litigation can itself be treated as evidence of bad faith.
At the same time, courts have been careful to distinguish between a genuine good-faith implementer who disagrees about the appropriate rate and is engaging seriously in negotiations and one that is simply delay-playing the system. The conditional injunction mechanism directing the implementer to deposit interim royalties into court or with the SEP holder as a condition of continuing to operate has become the Indian court’s preferred tool for balancing these competing concerns. The implementer can continue to sell devices while the final rate is litigated, but cannot use the technology for free during that period. This approach broadly mirrors the approach that the UK and German courts have adopted and is consistent with the direction of global jurisprudence following the UK Supreme Court’s landmark decision in Unwired Planet International Ltd. v. Huawei Technologies Co. Ltd. [2020] UKSC 37, which upheld global FRAND rates determined by a national court.
The Interface Between FRAND and Section 84: Compulsory Licensing as a Backstop
While Section 84 compulsory licensing has not yet been used in an SEP context in India, its potential application is a live strategic consideration. If an SEP holder’s FRAND offer is so far above a genuinely fair rate that the patented technology cannot be accessed at a reasonably affordable price, an implementer could, three years after patent grant, apply for a compulsory licence under Section 84(1)(b) of the Patents Act, 1970, on the ground that the invention is not available to the public at a reasonably affordable price. The Controller General would then have to determine what a reasonable price looks like a determination that would necessarily involve an assessment of FRAND principles from within the compulsory licensing framework.
This intersection has not yet been judicially worked out in India, but it matters because it creates a second pathway parallel to litigation before the Delhi High Court for challenging excessive SEP royalties. Whether the Controller General has the competence, resources and institutional capacity to make sophisticated FRAND rate determinations is an open question. The 2023 Delhi High Court judgment giving the Patents Act primacy over the Competition Act suggests that this pathway through the Controller’s office, rather than through the CCI, is where the legislature intends such disputes to be resolved.
Absence of an Express Statutory FRAND Framework and the Policy Gap One of the most significant structural problems with the current state of Indian SEP law is the complete absence of any legislative framework specifically addressing SEPs, FRAND commitments or the procedure for court-determined FRAND rates. Practitioners and courts are operating entirely on the basis of general patent law principles, judicially developed doctrine and analogies to foreign jurisprudence. This creates significant uncertainty, especially on questions such as: whether global FRAND rates can be determined by an Indian court (as in the UK), whether anti-suit injunctions can be sought in India to prevent foreign courts from determining FRAND rates applicable to Indian patents and what procedural mechanisms govern a FRAND rate determination trial.
The Department for Promotion of Industry and Internal Trade (DPIIT) and WIPO have both, at various points, conducted consultations on SEP policy. India’s National IPR Policy, 2016, acknowledged the importance of standards and technology access, but did not produce any specific SEP framework. In an era where 5G deployment is accelerating, where automotive connectivity and the Internet of Things are generating new classes of SEP disputes beyond mobile telecommunications and where India is positioning itself as a major hub of technology manufacturing, the absence of a coherent legislative or regulatory framework for SEPs is a serious gap that the policy-making apparatus will need to address.
What Practitioners and Implementers Must Know: The Practical Realities of Indian SEP Litigation
For a practitioner advising an Indian handset manufacturer, electronics company or any other implementer that receives a licensing approach from an SEP holder, several principles emerge from the body of Indian case law.
- The obligation to negotiate seriously and in good faith is real and has consequences. An implementer that delays, does not make counter-offers or initiates regulatory or litigation proceedings as a negotiating tactic risks being characterised as an unwilling licensee. Courts have shown willingness to grant conditional injunctions against implementers whose conduct demonstrates unwillingness to take a FRAND licence. The Intex Division Bench judgment is the clearest statement of this principle in Indian law.
- Challenging the essentiality of the asserted SEPs is a legitimate and important defence. The court in the Lava case spent considerable analytical energy on essentiality, ultimately accepting seven of Ericsson’s eight asserted patents as valid and essential. An implementer with technical expertise should engage in detailed claim-mapping analysis to assess whether the asserted patents are genuinely essential that is, whether implementing the standard necessarily involves practising each claim and should bring credible technical evidence to court. Courts are not equipped to accept essentiality on the SEP holder’s assertion alone.
- The royalty base and rate determination are both areas where technical economic evidence matters enormously. The court in the Lava case heard extensive expert testimony on comparable licences and royalty rate methodology. Implementers who wish to challenge a royalty demand as supra-FRAND must come with comparable licence data from their own agreements with other SEP holders and must present economic analysis that demonstrates why the demanded rate exceeds a FRAND benchmark. The court’s endorsement of the comparable licensing approach means that access to confidential licence data often protected by non-disclosure agreements is a central evidentiary challenge in these cases.
- The jurisdictional landscape remains unsettled pending the Supreme Court’s ruling on the CCI’s appeal against the Delhi High Court’s 2023 judgment. Until the Supreme Court rules, practitioners should be aware that the CCI has been held to lack jurisdiction over SEP licensing conduct by a patentee and that proceeding before the CCI may therefore not be a viable alternative to or supplement for licensing negotiations or litigation before the Delhi High Court.
Conclusion
India’s SEP and FRAND jurisprudence has, in the space of approximately a decade, grown from a state of near-complete absence to a reasonably developed body of doctrine that the international IP community is watching carefully. The Ericsson litigation spanning disputes with Micromax, Intex, iBall and Lava has produced interim orders, appellate guidance, a jurisdictional ruling of constitutional significance and now a final damages judgment that is the most detailed exposition of FRAND principles that any Indian court has yet delivered. The Delhi High Court has shown that it is willing to engage with the full complexity of SEP law essentiality determination, FRAND rate methodology, negotiating conduct and the interaction between patent rights and competition principles and has produced reasoning that can stand comparison with leading jurisdictions.
But the fundamental challenges remain. There is still no statutory definition of Standard Essential Patents in India, no legislative framework for FRAND obligations or their enforcement and no specialised tribunal with the technical and economic capacity to conduct sophisticated FRAND rate determinations efficiently. The Supreme Court’s ruling on the CCI jurisdiction question will be transformative whatever the outcome: if the Patents Act is confirmed as the primary vehicle, the Controller General’s office will need to develop significantly greater capacity; if the Competition Act is held to apply concurrently, a whole new regulatory channel for challenging SEP royalties will open. India’s trajectory as a major technology manufacturing economy competing with China and Vietnam for global electronics supply chain investment makes the resolution of these questions urgent not just as a matter of IP law, but as a matter of economic strategy. The courts have begun the work. The legislature and the regulator must follow.
References
- Patents Act, 1970 (as amended) – https://ipindia.gov.in/writereaddata/Portal/IPOAct/1_31_1_patent-act-1970-11march2015.pdf
- Competition Act, 2002 – https://www.indiacode.nic.in/handle/123456789/2010
- Lava International Ltd. v. Telefonaktiebolaget LM Ericsson, 2024 SCC OnLine Del 2497 – https://www.wipo.int/wipolex/en/judgments/details/2159
- Telefonaktiebolaget LM Ericsson v. Competition Commission of India, 2023 SCC OnLine Del 4078 – https://www.ssrana.in/articles/telefonaktiebolaget-lm-ericsson-publ-vs-competition-commission-of-india/
- ETSI IPR Policy – https://www.etsi.org/intellectual-property-rights
- WIPO – Standard Essential Patents and FRAND Licensing – https://www.wipo.int/patents/en/topics/essential_patents.html
- WTO TRIPS Agreement, Articles 27–34 – https://www.wto.org/english/docs_e/legal_e/27-trips_04d_e.htm
- DPIIT – National IPR Policy, 2016 https://dpiit.gov.in/sites/default/files/National_IPR_Policy_English.pdf
- CGPDTM – Patent Office Annual Report https://ipindia.gov.in/annual-report.html
- Competition Commission of India Orders and Decisions – https://www.cci.gov.in/antitrust/orders/details
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