Position Papers
Working to protect the rights of companies and individuals who invest and innovate in the digital world.
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Artificial Intelligence
The Developers Alliance strongly supports the need for an increased knowledge and awareness on AI technology and for ensuring the right skills for the workforce. Knowledge and awareness of the complexity of AI is needed at the policy-making level in order to avoid regulatory responses made in haste, based purely on political impulses. Any potential regulation would need to be adaptive and principle-based in order to ensure that the economy and society in general enjoys the benefits of AI.
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Developers Alliance Co-sign, Alongside Five Other Tech Industry Associations, a Joint Statement on the Latest Developments of the Negotiations on the Artificial Intelligence Act (AI Act)
Read MoreThe statement addresses concerns about the direction of the latest proposals to regulate General Purpose AI (GPAI) systems and AI Foundation models. The current proposals do not take into account…
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Artificial Intelligence Act – Key Points for the Last Mile of the Legislative Process
Read MoreAs the last phase of the legislative process unfolds, Developers Alliance reminds the EU co-legislators of several essential aspects:
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Developers Alliance’s feedback on the European Commission’s proposal for an Artificial Intelligence Liability Directive (AILD)
Read MoreDevelopers Alliance recognizes the proposal for a Directive on adapting non-contractual civil liability rules to artificial intelligence (AI Liability Directive – AILD) in relation to the implementation of the AI Act….
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Additional External Resources: Developers Alliance Submitted Feedback On The European Commission’s Proposal For A Regulation On Machinery Products
Read MoreDevelopers Alliance welcomes the opportunity to provide feedback on the proposal for a Regulation on Machinery Products. We limit our observations to elements implicating software and software developers.
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Developers Alliance’s Releases Position On The European Commission’s Proposal For A Regulation On Artificial Intelligence (AI Act)
Read MoreWe commend the objectives and the risk-based approach ofthe Commission’s proposal. We call on the EU co-legislators,however, to address a series of critical issues so theregulation will be fit for…
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The Developers Alliance Preliminary Assessment Of The European Union Artificial Intelligence Act Proposal
Read MoreThe regulation of AI systems that cause severe harm, as well as use restrictions onsurveillance and social monitoring applications, is consistent with the softwarecommunity’s focus on building trust in the…
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Response To The Inception Impact Assessment For A Legal Act Of The European Parliament And The Council Laying Down Requirements For Artificial Intelligence
Read MoreThe Inception Impact Assessment (IIA) presents several regulatory options and theunderlying policy objectives, based on the approach initiated by the White Paper on AI.Our response emphasizes the need to avoid…
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Our Submission To The European Commission’s Consultation On The White Paper On AI
Read MoreWe support the twin objectives proposed by the White Paper. Our comments and suggestionsrefer to the appropriate approach to meet these objectives based on the expertise of thesoftware developers that…
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Our Standpoints On The EC’s White Paper On AI
Read MoreOur Standpoints On The EC’s White Paper On AI Update: The economic circumstances due to the Coronavirus crisis imposes a new perspective. Technology innovation represents the key solution for future…
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Position On The Opinion Of The German Data Ethics Commission (DEK)
Read MorePosition On The Opinion Of The German Data Ethics Commission (DEK) # (as yet) this position is based on the Executive Summary (English translation) # it focuses mainly on the…
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Position On EU “Trustworthy AI” Debate
Read MoreDevelopers Alliance welcomes the debate at EU level and the efforts of the High Level Expert Group on AI (AI HLG) to debate and refine the “Ethics Guidelines for Trustworthy…
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Our AI HLEG Trustworthy Assessment List Contribution Standpoints
Read MoreThe standpoints of our contribution to the piloting process on the Trustworthy Assessment List, developed by the AI HLEG. Overall there is no clear evidence on the relevance and feasibility…
Digital Platform Competition
Healthy companies that invest and innovate are integral to a successful developer ecosystem. Policy makers must recognize that traditional market risks do not automatically apply in the hyper-competitive digital space. Concepts of scarcity and finite distribution networks are far less relevant, and absent actual market failures it is inappropriate to extrapolate based on hard-goods market history. Consumer benefits are the most appropriate measure of a functioning market; one complete with developers, content creators, consumers, and the platforms and networks that interconnect them.
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Developers Alliance Open App Markets Act Assessment
Read MoreAt the outset, we find the abstract category of “general-purpose computing device”unnecessary and legally confusing. Any computing ecosystem that includes an app store ofappropriate scale supporting 3rd party applications for…
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Developers Alliance Statement On President Biden’s Executive Order on Promoting Competition in the American Economy
Read MoreWhile we believe many of these sweeping reforms positively impact developers, we encourage the Administration to not act in haste with regards to major policy changes as increased regulation can unintentionally, negatively impact a rapidly growing ecosystem.
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Rhode Island Senate Bill No. 770 Will Harm Developers
Read MoreOn behalf of the Developers Alliance, I write to offer our views on how SB 770 wouldundermine a thriving ecosystem of application developers and technology services that hashelped the United…
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Developers Alliance’s Position Paper On The Digital Markets Act (DMA)
Read MoreWe welcome a harmonized approach, which should be strengthened by anappropriate mechanism of cooperation with the national authorities, in particularnational competition authorities (sparsely addressed by art. 32 – The Digital…
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Louisiana House Bill No. 518 Will Harm Developers
Read MoreOn behalf of the Developers Alliance, I write to offer our views on how HB 518 wouldundermine a thriving ecosystem of application developers and technology services that hashelped the United…
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Response To The Subcommittee on Competition Policy, Antitrust, and Consumer Rights Hearing on “Antitrust Applied: Examining Competition in App Stores”
Read MoreWe write to express the views of software developers with regards to the hearing examiningcompetition in app stores. The Developers Alliance represents over 70,000 developers from 50states and many countries…
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Developers Alliance Position On The Digital Services Act (DSA)
Read MoreThe Digital Services Act represents an opportunity to have an updated andharmonized framework for providing digital services across the EU. This willbenefit all internet businesses, including those of software developers.
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Rhode Island House Bill 6055 Will Harm Developers
Read MoreOn behalf of the Developers Alliance, I write to offer our views on how HB 6055 wouldundermine a thriving ecosystem of application developers and technology services that hashelped the United…
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Developers Alliance’s Letter to House Judiciary re: Pt 1 Gatekeeper Hearing
Read MoreOn behalf of all developers, we commend your committee’s initiative for tackling thecomplex issue of addressing competition policies as they pertain to the technologyindustry. The Developers Alliance supports developers and…
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Arizona House Bill 2005 Will Harm Developers
Read MoreOn behalf of the Developers Alliance, I write to offer our views on how HB 2005 wouldundermine a thriving ecosystem of application developers and technology services that hashelped the United…
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The Developer Community’s Thoughts on App Stores and the App Ecosystem – Submission to the Australian Competition & Consumer Commission
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Developers Alliance feedback on the inception impact assessment (IIA) on the 1
New Competition Tool (‘NCT’)Read MoreBusinesses, no matter the size and the market they’re active in, need a balanced andpredictable environment. Obviously, software developers feel no different. They need to knowthe rules of the game,…
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Developers Alliance’s Position on the Digital Services Act Package
Read MoreDevelopers Alliance welcomes the opportunity to submit feedback to the European 1Commission’s (EC) open public consultation on the Digital Services Act package.The present position paper is structured according to the…
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Developers Alliance’s feedback to the public consultation on a New Competition Tool
Read MoreThe technology industry represents an essential part of the economy today. Softwaredevelopment and the consequent digital transformation have expanded exponentially,permeating all other sectors. The challenges of the dynamic markets associated…
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Developers Alliance Standpoints On The Digital Services Act And The Digital Markets Act
Read MoreThe revision of the e-Commerce Directive represents the right moment to ensure an updatedharmonized legal framework for online content. It should preserve the core principles that enablethe open internet and…
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Infographic on developers survey on Platform-to-Business relationships
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Position on the European Commission’s proposal for Regulation on promoting fairness and transparency for business users of online intermediation services
Read MoreThe Developers Alliance represents software developers and the companies invested in their success.The Alliance’s members include businesses of all sizes that are leaders in consumer, enterprise,industrial, and emerging software development,…
Data & Privacy
As the European Parliament and Council work to draft an ePrivacy Regulation the Alliance is working with stakeholders and policymakers to avoid unnecessary constraints to data uses and innovation. As it stands, the new framework sets a new and unnecessarily burdensome standard for securing online communications and tracking confidentiality. Policies, no matter how well intended, that overzealously limit communication and content data collection have an enormously negative affect on small businesses and software developers. We continue to work with the industry and parliament (see our ePrivacy proposal letter) to find a solution that does not hamper developer’s ability to innovate.
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Developers Alliance’s Position On The Proposal For A Regulation On European Data Governance (Data Governance Act)
Read MoreThe proposal represents one of the first legislative measures under the EuropeanStrategy for Data. It is intended to create a framework for facilitating access to public dataand the sharing of…
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Developers Alliance Issues Statement Regarding Kids PRIVACY Act
Read MoreThe developer advocate agrees with the strengthening of child protections online but finds the proposal lacks clarity and reduces legal certainty.
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Developers Alliance Joins Coalition Expressing Concern Over Draft EU-UK Adequacy Negative Vote
Read MoreThe leading software developer advocate joins a global industry coalition expressing concern regarding the looming EU-UK data flow interruption.
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Developers Alliance feedback on the inception impact assessments (IIAs) for the Digital Services Act Package
Read MoreThe Platform-to-Business Regulation (EU) 2019/1150 already responds to issues faced bydevelopers and other small businesses in the online platform environment. It provides them notonly much needed transparency, but requires online…
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Developers Alliance’s feedback to the European Commission’s Inception Impact Assessment on the Revision of the eIDAS Regulation – European Digital Identity (EUid)
Read MoreDevelopers Alliance’s feedback to the European Commission’s Inception Impact Assessment on the Revision of the eIDAS Regulation – European Digital Identity (EUid). Developers Alliance advocates on behalf of software developers…
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Contribution To The European Commission’s Consultation On The European Strategy For Data
Read MoreThe approach proposed by the strategy partially meets these objectives. Invoking the need topromote “European values”, it inappropriately focuses on “more data being stored andprocessed in the EU,” increasing the…
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Our Standpoints On The European Strategy for Data
Read MoreOur Standpoints On The European Strategy for Data Update: The economic circumstances due to the Coronavirus crisis imposes a new perspective. Technology innovation represents the key solution for future economic…
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Developers Alliance Standpoints On The Digital Services Act And The Digital Markets Act
Read MoreThe revision of the e-Commerce Directive represents the right moment to ensure an updatedharmonized legal framework for online content. It should preserve the core principles that enablethe open internet and…
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We signed on to a joint industry letter on the ePrivacy proposal, asking policymakers to reconsider it.
Read MoreThe draft ePrivacy Regulation was proposed in January 2017 and remains on the agenda of theCouncil of the EU following two and a half years of intense discussions. Progress on…
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Updated position paper on the Proposal for an E-Privacy Regulation
Read MoreThe Developers Alliance represents software developers and the companies invested in their success.The Alliance’s members include businesses of all sizes that are leaders in consumer, enterprise,industrial, and emerging software development,…
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Infographic on the Practical Consequences of the E-Privacy Regulation
Read MoreTHE PRACTICAL CONSEQUENCES OF THE PROPOSED E-PRIVACY REGULATION
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Position paper on the Proposal for an E-Privacy Regulation
Read MoreThe Developers Alliance represents software developers and the companies invested in their success.Alliance’s members include businesses of all size, that are leaders in consumer, enterprise, industrial,and emerging software development, along…
Trade and Cross Border Data
The free-flow of data is fundamental to a vibrant digital economy. Like other trade barriers, impediments which restrict the flow of data across borders create fragmented and inefficient markets without scale economies, stifle innovation, limit competition, and drive up consumer costs. We recommend policy makers focus on reinforcing the existing umbrella agreement while simultaneously engaging in dialog in support of harmonized privacy principles in the digital realm.
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Developers Alliance Joins Global Coalition Backing WTO’s E-commerce Initiative
Read MoreDevelopers Alliance has joined a multi-association coalition in support of the World Trade Organization (WTO) Joint Initiative on E-commerce (JSI) negotiations. The associations represent technology companies active across the world…
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Developers Alliance Feedback To The European Commission’s Consultation “A Renewed Trade Policy For A Stronger Europe”
Read MoreIn every area of their digital business, software developers rely on global trade. Softwaresolutions are developed in a collaborative environment, often at a global level. Developerbusinesses participate alongside platforms and…
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Developers Alliance Joins Coalition Expressing Concern Over Draft EU-UK Adequacy Negative Vote
Read MoreThe leading software developer advocate joins a global industry coalition expressing concern regarding the looming EU-UK data flow interruption.
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Developers Alliance Joins Other Tech Sector Bodies Calling For New Impetus In Global Talks On Digital Taxation
Read MoreWith the new US administration comes the opportunity to build international consensus on the taxation of the digital economy. Prolonging national digital tax discussions risks driving international trade disputes.
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Developers Alliance Joins With Global Business Community To Call On EU To Safeguard International Data Flows
Read More“International data flows are an integral pillar of global trade, and any disruption to their free flow constitutes a major challenge to every economic sector,” the groups wrote in the letter sent Monday.
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Developers Alliance Joins Global Privacy And Data Experts Asking EU and U.S. For Legal Certainty In Cross-Border Data Transfers
Read MoreThe Cross-discipline groups warn of disruption between EU and U.S. data-transfers should amenable agreements not be met.
Expanded Work
The topics listed to the side are far less than the breadth of issues that affect the developer community, and can’t capture the entirety of our work. From intellectual property law to trade agreements to immigration, technology touches everything in our society, and so does the developer community.
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Key Points for the Revision of the Product Liability Directive
Read MoreThe revision of the Product Liability Directive (PLD) was presented as a targeted update of the harmonized framework for a strict liability regime for products in the EU. The proposal…
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Developers Alliance Has Submitted Its Comments to the European Commission’s Consultation Regarding the Legislative Proposal for a Cyber Resilience Act.
Read MoreBrussels, EU, January 23th, 2023 – The Developers Alliance announces the submission to the European Commission’s Consultation regarding The Cyber Resilience Act. The Cyber Resilience Act introduces harmonized essential cybersecurity…
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Developers Alliance’s position on the European Commission’s proposal for a new Product Liability Directive
Read MoreDevelopers Alliance expresses several concerns related to the revision of the Product Liability Directive (PLD). The EU proposal extends the strict liability for defective products and the conditions for compensation claims in…
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Developers Alliance Joins Amicus Brief to Ensure Patent System Works to Foster Innovation
Read MoreThe Developers Alliance, along with Engine and ACT | The App Association encourages the PTO and Patent Trial and Appeal Board (PTAB) to focus on patent validity to alleviate potential…
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Developers Alliance Feedback On The European Commission’s General Product Safety Directive – Review
Read MoreDevelopers Alliance appreciates the opportunity to provide input to the consultation on the proposal for a Regulation on general product safety. Our comments are strictly limited to aspects related to…
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Additional External Resources: Developers Alliance Feedback On The European Commission’s General Product Safety Directive – Review
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Re: Request for Comments on Discretion To Institute Trials Before the Patent Trial and Appeal Board – US Patent and Trademark Office
Read MorePatent litigation is on the rise again following the NHK Spring Co. v. Intri-Plex Techs., Inc. case. PAE’s are taking advantage of this precedent to flood the court system with…
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Developers Alliance’s feedback to the European Commission’s Inception Impact Assessment on the Revision of the eIDAS Regulation – European Digital Identity (EUid)
Read MoreDevelopers Alliance’s feedback to the European Commission’s Inception Impact Assessment on the Revision of the eIDAS Regulation – European Digital Identity (EUid). Developers Alliance advocates on behalf of software developers…
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Developers Alliance Feedback On The European Commission Roadmap For The IP Action Plan
Read MoreDevelopers Alliance welcomes the opportunity to provide feedback on the European Commission’s roadmap for the IP Action Plan. Developers Alliance advocates on behalf of software developers and the companies invested…
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