BSA | The Software Alliance appreciates the opportunity to respond to the Advance Notice of Proposed Rulemaking (ANPRM) published on April 21, 2023 by the US Patent and Trademark Office (USPTO) and entitled, “Changes Under Consideration to Discretionary Institution Practices, Petition Word-Count Limits, and Settlement Practices for America Invents Act Trial Proceedings Before the Patent Trial and Appeal Board” (PTAB).