The Intellectual Property Owners Association (IPO)  has submitted bilingual comments to SAMR on the draft Trade Secret Rules 《商业秘密保护规定（征求意见稿) 》.   The comments are found here and at the IPO website   I blogged about these rules previously here. 

IPO’s substantive trade secret comments on a range of issues governed by both the Phase 1 Trade Agreement and emerging best practices are especially welcome. In my view, IPO also correctly notes that “[t]he Draft Rules contemplate an expansive role for administrative authorities in connection with trade secret enforcement.” It properly advocates for harmonization with the people’s courts in such matters as “uniformity, predictability, transparency, oversight, and procedural protections that are provided to the affected parties through judicial review.”   IPO also notes that rule making like this would be better if accomplished through than State Council Regulations to ensure that they are sufficiently authoritative.  I also agree. 

Thank you IPO for making these publicly available!