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Peter J. CampCounsel, C2ISR Programs DivisionUSAF Electronic Systems Center

Matthew J. KleimanCorporate CounselDraper Laboratory

Software & Data Rights in Government Contracts

NCMA WorkshopMarch 16, 2011

The views expressed are those of the presenters and may not reflect the policy or position of the DOD, USAF or Draper Laboratory

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Outline

What is Intellectual Property? Background on FAR & DFARS Software

and Data Rights FAR Software & Data Rights Provisions Industry Tips

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WHAT IS INTELLECTUAL PROPERTY?

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Intellectual Property

Valuable intangible property created by the human mind

Provided for in the Constitution To promote the progress of science and useful arts, by

securing for limited times to authors and inventors the exclusive right to their respective writings and discoveries. Art. 1, sec. 8, cl. 8

What is IP?

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Intellectual Property

Patent: Property right granted by the government to an inventor which allows the inventor to exclude others from making, using or selling the invention

Copyright: Set of exclusive rights granted to the author or creator of an original work of authorship, including the right to copy, distribute and adapt the work

Trade Secret: A formula, process, design, instrument or other information which is not generally known or reasonably ascertainable, by which a business can obtain an economic advantage over competitors

Trademarks: A distinctive sign or indicator used in the marketplace to distinguish goods or services of one source from those of other sources

What is IP?

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A Real US PatentU.S. Patent #6,293,874: User-Operated Amusement Apparatus for Kicking the User’s Buttocks

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BACKGROUND ON

FAR & DFARS SOFTWARE AND DATA RIGHTS

Purpose

Gain a basic understanding of FAR and DFARS Data

Rights treatment so you can negotiate fair

and reasonable terms

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Background

Different Rules for

Civilian Agencies (FAR) v. DOD (DFARS)

Technical Data v. Computer Software

Commercial Items v. Non-Commercial Items

FAR & DFARS Data and Software Rights

1955 20071987

1988

1995

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FAR/DFARS SOFTWARE & DATA RIGHTS PROVISIONS

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FAR Software & Data Rights Policy

Acknowledges that agencies require data to: Obtain competition among suppliers Fulfill responsibilities for disseminating the results of their activities Ensure appropriate utilization of the results of research, development,

and demonstration activities, including the dissemination of technical information to foster subsequent technological developments

Meet other programmatic and statutory requirements Meet specialized acquisition needs and ensure logistics support

Recognizes that contractors have proprietary interests in data and that the protection of such data is necessary to encourage contractors to participate in Government programs Agencies shall protect proprietary data from unauthorized use and

disclosure Agencies shall balance the Government’s needs and the contractor’s

legitimate proprietary interests

FAR 27.402

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References 10 U.S.C. §§ 2302(4), 2305(d)(4),

2320, 2321 and 2325 FAR Subpart 27.4 DFARS Subparts 227.400, 227.71, 227.72

–252.227-7013 (technical data)

–252.227-7014 (computer software and documentation)

http://www.acq.osd.mil/dpap/Docs/intelprop.pdf

DOD Policy

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Data

FAR Recorded information, regardless

of form or media Includes technical data and

computer software Does not include information

incidental to contract administration, such as financial, administrative, cost or pricing, or management information

Confidential financial information may be protected under the Trade Secrets Act and exemptions to the Freedom of Information Act

DFARS (Not defined)

FAR 52.227-14(a); DFARS 252.227-7013(a)(14)

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Technical Data

FAR Data, other than computer

software, which are of a scientific or technical nature

Does not apply to the item or component itself

Includes data bases and computer software documentation

Excludes computer software or financial, administrative, cost or pricing, or management data or other information incidental to contract administration

DFARS Data, other than computer

software, which are of a scientific or technical nature

Does not apply to the item or component itself

Includes data bases and computer software documentation

Excludes computer software or financial, administrative, cost or pricing, or management data or other information incidental to contract administration

FAR 52.227-14(a); DFARS 252.227-7013(a)(14)

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Computer Software

FAR Computer programs that comprise

a series of instructions, rules, routines or statements, regardless of the media in which recorded, that allow or cause a computer to perform a specific operation or series of operations

Recorded information comprising source code listings, design details, algorithms, processes, flow charts, formulas, and related material that would enable the computer programs to be produced, created, or compiled

Excludes data bases and computer software documentation

DFARS Computer programs (a set of

instructions, rules, or routines recorded in a form that is capable of causing a computer to perform a specific operation or series of operations), source code, source code listings, design details, algorithms, processes, flow charts, formulae and related material that would enable the software to be reproduced, recreated, or recompiled.

Excludes computer data bases and computer software documentation.

FAR 52.227-14(a); DFARS 252.227-7013(a)(3)

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Comp. Software Documentation

Owner’s manuals, user’s manuals, installation instructions, operating instructions, and other similar items, regardless of storage medium, that explain the capabilities of the computer software or provide instructions for using the software

FAR 52.227-14(a); DFARS 252.227-7014(a)(5)

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Who gets what?

Title --» Contractor Rights grant --» Government

Unlimited rights (default) (FAR 27.404-1)– Data first produced in the performance of a contract

Limited rights (in technical data) (FAR 27.404-2(c))– Technical Data produced at private expense containing confidential

information Restricted rights (in computer software) (FAR 27.404-2(d))

– Computer Software (non-commercial) produced at private expense containing confidential or privileged information

Government purpose rights (FAR 27.408)– Co-sponsored R&D

FAR

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Who gets what?

Title --» Contractor License --» Government

Unlimited rights (-7013(b)(1) & -7014(b)(1))– Including FF&F; OMIT; developed exclusively w/ Fed funds; specified as

element of performance; publicly available; by K/expir. of GPR Limited rights (in technical data) (-7013(b)(3)) No Expiration

– Technical Data developed exclusively at private expense and marked with the limited rights legend

Restricted rights (in computer software) (-7014(b)(3)) No Expiration– Computer Software (non-commercial) required to be delivered or otherwise

provided to the Gov’t under the K that were developed exclusively at private expense

Government purpose rights (-7013(b)(2) & -7014(b)(2)) 5 Year Expr’n– Developed with mixed funding but without Unlimited Rights

– Developed with mixed funding in performance of K that doesn’t require dev’t; mfr; construction; or production of items, components, or processes

DFARS 252.227-7013 (TD) & -7014 (CS)

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Data Rights Spectrum

UnlimitedRights

Govt Funding

GPR

Mixed Funding

Limited/RestrictedRights

PrivatelyFunded

Restrictions

Least Most

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FAR & DFARS Unlimited Rights

Unlimited Rights: The right of the Gov’t to use, modify, perform, disclose, reproduce, prepare derivative works, distribute copies to the public, and perform publicly and display publicly, in any manner and for any purpose, and to have or permit others to do so (52.227-14(a); -7013/-7014(a)(15)) Gov’t can publish Data on the front page of the Boston Globe

Applies to (52.227-14(b)(1); -7013/-7014(b)(1)), including: Data first produced in the performance of a contract TD/CS developed exclusively with Government funds Studies, analyses, test data, etc. as an element of K performance CS documentation deliverables Expired GPR Form, fit, and function data delivered under contract Manuals or instructional and training material

Default Rule for Data

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FAR Limited Rights

Limited Rights Data (LRD): Developed at private expense and embodies trade secrets or are commercial or financial and confidential or privileged (52.227-14(a))

Default rule is that Contractor may withhold LRD from the Gov’t and deliver form, fit and function data instead (52.227-14(g))

Alt. II – Allows Contractor to deliver LRD with Limited Rights Gov’t may reproduce or use LRD Gov’t may not

– disclose LRD outside the government

– use LRD for manufacturing Other permitted uses may be listed in the Limited Rights Notice

LRD must be marked with Limited Rights Notice in Alt. II

Technical Data

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Limited Rights: Government can make internal use of data, but cannot disclose outside the Government We may only share the information with other federal

employees. If we need to share it with contractors or other non-government personnel, we must get the written permission of the owner of the data, and the recipient must sign a non-disclosure agreement

– Exception: Emergency repair or overhaul No expiration

DFARS Case 2009–D031 Permits support contractors to access third party

Technical Data, conditioned upon the execution of an NDA with the owner of the Technical Data

DFARS Limited RightsTechnical Data: DFARS 252.227-7013(a)(13)

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Restricted Rights: Generally restricts the Government’s use to a single computer per copy of the software, and prohibits all but backup or archival copies

– Exception: Emergency repair or overhaul Contractors performing service contracts may

access restricted rights software in certain situations provided that:– Govt notifies the party asserting restricted rights, and– The support contractor is subject to 227.7103-7 or

252.227-7025– See clause for details; consult legal as needed

No expiration

DFARS Restricted RightsNoncommerical Computer Software (CS): DFARS 252.227-7013(a)(13)

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FAR Restricted Rights

Restricted Computer Software (RCS): Developed at private expense and that is a trade secret, is commercial or financial and confidential or privileged, or is copyrighted computer software (52.227-14(a))

Default rule is that Contractor may withhold RCS from the Gov’t and deliver form, fit and function data instead (52.227-14(g))

Alt. III – Allows Contractor to deliver RCS with Restricted Rights Use on the computer for which it was acquired Use on a back up computer Archive and backup copies Modify, adapt or combine with other software Disclose to service support contractors Use on replacement computer

RCS must be marked with Restricted Rights Notice in Alt. III

Computer Software

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FAR Government Purpose Rights

Use in contracts where: Co-sponsored research & development; Contractor required to make substantial contributions of funds or

resources (e.g., by cost-sharing or by repayment of nonrecurring costs); and

Contractor’s and the Government’s respective contributions are not readily segregable

Government Purpose Rights should, at a minimum, assure use of the data for agreed-to Governmental purposes

Used in Cooperative Research and Development Agreements (CRADAs)

Co-Sponsored R&D – 27.408(a)

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DFARS Government Purpose Rights

Government Purpose Rights (GPR): Permit the Government to use, modify, reproduce, release, perform, display tech data within the Govt without restriction; and to release or disclose tech data outside for Govt Purposes

“Government Purpose” includes competitive procurement, but do not the rights to use,

modify, reproduce, release, perform, display, or disclose technical data for commercial purposes or authorize others to do so

Govt may not disclose unless– Recipient is subject to Use & Non-Disclosure Agreement at

DFARS 227.7103-7; or– Recipient is a Govt contractor receiving data for performance of

a Govt contract that contains 252.227-7025 Applies to tech data and software Expires in 5 yrs unless otherwise negotiated, converts to Unlimited

DFARS 252.227-7013(a)(12)/-7014(a)(11)

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FAR & DFARS Commercial Software

Commercial Item definition (FAR 2.101): Any item, other than real property, of a type customarily used for

nongovernmental purposes, that is– sold, leased or licensed to the general public; or

– offered for sale, lease or license Modifications of a type customarily available in the commercial marketplace Minor modifications of a type not customarily available in the commercial

marketplace made to meet Federal Government requirements Compliance with the FAR requirements excused (27.405-3(a)) Government acquires commercial software under the license

customarily provided to the public Limitation: To the extent the license is consistent with Federal law and

otherwise satisfies the Government’s needs Do not use FAR Commercial Software clause (52.227-19)

Unlimited rights in data Restricted rights in software

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Commercial Items

DFARS 227.7102-1(a): DoD shall only acquire the tech data customarily provided to the public with a commercial item, except tech data that Are form, fit, or function data Are required for repair, maintenance or installation or

customary data is not sufficient for military purposes Describe mods to commercial items made at Govt

expense to meet Govt requirements Section 2320(b)(1) of Title 10 U.S.C. establishes

the presumption that commercial items are developed at private expense

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DFARS Specifically Nego’d Rights

Specifically Negotiated Rights: Any rights negotiated by the contractor and agency that are different than the foregoing classes of rights

Also called “Special” or “Non-standard” Rights Govt may not accept less than statutory rights without

receiving a “compensating benefit” Degree to which these are permitted depends on the

particular regulations applicable to the procurement Must be identified in a license agreement incorporated

into the contract Coordinate with Legal Applies to tech data or software Expiration negotiated

DFARS 252.227-7013(b)(4)

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FAR Release of Data

Contractor shall have the right to use, release to others, reproduce, distribute or publish any data first produced or specifically used by the Contractor in the performance of this contract, except: As prohibited by Federal law (e.g., export control or national security); As expressly set forth in this contract; or Data that contain restrictive markings shall be treated in accordance with

such markings.

(52.227-14(d)) Contractor may not assert copyright in contract data without CO

permission, except for scientific and technical data for publication in academic, technical or professional publications (52.227-14(c))

Alt. IV – Contractor may assert copyright in all contract data

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INDUSTRY TIPS

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Subcontracts

Case Study: Sub discloses confidential technical data to Prime while working

on Phase I of a DOD program Subcontract incorporates by reference DFARS 252.227-7013,

including the provision that the Prime is to have “unlimited rights in technical data that are … developed exclusively with Government funds”

In the process of soliciting bids for Phase II of the program, Prime discloses Sub’s technical data to Sub’s competitor

Sub sues Prime for misappropriation of trade secrets Will the Sub’s misappropriation claim be successful?

Case Study - Flowdowns

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Subcontracts

Plainville Electrical Products Co. v. Bechtel Bettis Inc.

(D.Ct. 2009) Court: “Because the 2003 subcontract gave [Prime] the

unlimited right to use, distribute, or disclose that data … there can be no ‘misappropriation’ of the [Sub’s] data, and therefore no trade secret claim.”

Court emphasized that the “DFARS provides a mechanism for protecting trade secrets that the parties chose not to use.”

Case Study - Flowdowns

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Subcontracts

Subcontracts are commercial agreements – negotiate! Exception: Mandatory flow-down provisions

Avoid “mindless flowdowns” Do not simply replace “Government” with “Prime Contractor” in Patent and

Data & Software Rights clauses FAR 52.227-11(k)(3): “At all tiers, the patent rights clause must be

modified to identify the parties as follows: references to the Government are not changed, and the subcontractor has all rights and obligations of the Contractor in the clause. The Contractor shall not, as part of the consideration for awarding the subcontract, obtain rights in the subcontractor’s subject inventions.”

DFARS 252.227-7038(l)(2)(i): “The patents rights clause included in the subcontract shall retain all references to the Government and shall provide to the subcontractor all the rights and obligations provided to the Contractor in the clause. The Contractor shall not, as consideration for awarding the subcontract, obtain rights in the subcontractor’s subject inventions.”

Mindless Flowdowns

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Subcontracts

Prime’s rights to Sub’s IP should be limited to those rights that are necessary to perform the contract

FAR 52.227-14(h): The Contractor shall obtain from its subcontractors all data and rights therein necessary to fulfill the Contractor’s obligations to the Government under this contract

DFARS 252.227-7013(k): – (2)Technical data required to be delivered by a subcontractor or supplier shall

normally be delivered to the next higher-tier contractor, subcontractor, or supplier. However, when there is a requirement in the prime contract for data which may be submitted with other than unlimited rights by a subcontractor or supplier, then said subcontractor or supplier may fulfill its requirement by submitting such data directly to the Government, rather than through a higher-tier contractor, subcontractor, or supplier.

– (4)The Contractor and higher-tier subcontractors or suppliers shall not use their power to award contracts as economic leverage to obtain rights in technical data from their subcontractors or suppliers.

Prime does not need the same rights as the Gov't Standard NDA terms are often sufficient

Scope of Rights Granted to Prime Contractor

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Subcontracts

In the course of performing a DOD program, Contractor gives source code that it developed at private expense to the Government, but did not assert rights to the software or include any proprietary markings

Key employee leaves Contractor and starts a competing business with core technology based on source code

Contractor files a lawsuit against the former employee for misappropriation of trade secrets.

Case Study – Grant of Rights to the Government

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Subcontracts

L-3 Comm. Westwood Corp v. Robichaux (E.D. La. 2008) Court: “Granting the Gov't unlimited rights to data without any restrictive

legend or markings constitutes a failure to maintain secrecy” Because contractor “did not use efforts reasonable under the

circumstances to maintain the secrecy of the alleged trade secrets in the source code,” the source code was no longer protectable as a trade secret

Carefully consider the nature of the rights granted to the Gov't Giving the Gov't “unlimited rights” when IP is developed at private

expense can impact the status of those rights vis-à-vis third parties

Scope of Rights Granted to the Government

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Monitor the Engineers

Strategic development decisions Must make smart decisions about what to develop at private

expense and what to develop with public funds and what to develop in the performance of a government contract

Track development process Only deliver technical data and software that is required

by the contract Marking/Notice

Must provide notice and mark data exactly as required Unlabeled or improperly marked data is unlimited rights data Proposal must include table identifying what data/software is

being provided with other than unlimited rights

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Marking

Properly mark all data and software as required by the contract Standard confidential/proprietary markings are not sufficient

Night Vision Corp. v. U.S. (Fed. Ct. Cl. 2005) Contractor waived any protection from disclosure of data rights when it

delivered prototypes to the Gov't without marking the prototypes or their packaging with appropriate legends

Court: “To read an exception into the regulation … would undermine the entire purpose of restrictive legends. Restrictive legends alert all Gov't officials [that] data is considered proprietary and is inappropriate for dissemination. Creating exceptions to the restrictive rights requirement would place Gov't officials in the difficult position of being unsure which data was subject to restrictions and which was not”

Cautionary Tales

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Government Best Practices & Responsibilities

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Sustainment

Data rights are still important in a sustainment environment

To sustain a system, the Govt must know what category of data rights it has to the existing data

A modification to an existing system must consider the category of data rights to obtain for sustainment

In the acquisition planning phase of any sustainment acquisition, data rights issues must be considered

Due to the length of sustainment activity that may occur on a system, data rights are important in the support of the system

Data Rights Acquisition Process Overview

Requirements/ Acq Planning

• Data Manager and PM determine data rights required. Considerations: contractors’ economic interest, Government’s costs, re-procurement needs, future uses of data, need to disseminate research results etc.

Acq Plan/ASP

• Data rights requirements and strategy are clearly documented and approved

Solicitation

• Govt’s desired data rights specified in solicitation

• Section J, Exhibit A contains three tables that are the heart of the data rights approach

• Section K contains provision DFARS 252.227-7017

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Data Rights Acquisition Process Overview (con’t)

Evaluation Phase

• Data rights assertions in Section K are reviewed by tech team (verification tools: lit search, DTIC, personal knowledge, other Govt personnel, DCMA, etc.)

• If necessary, clarification is requested from contractor

• Specifically negotiated license rights coordinated with JA

Negotiation/ Award Phase

• If warranted, assertions are challenged by PCO then coordinated with Govt team

• Data rights are clearly captured in an attachment to the contract

Performance Phase

• Contractor can make assertions arising during performance

• New assertions must be incorporated into contract

• Monitor deliverable data to ensure markings are IAW contract

• Non-conforming/ unjustified data markings worked with PCO.

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Data Rights Acquisition Process Overview (con’t)

Data Delivery

• PM/Data Inspector inspects data rights markings

• Reports non-conforming and unjustified markings to PCO for action

• PCO engages legal as needed

Post-Performance

• Government may challenge restrictive markings within 3 years of contract completion

• Don’t rely on this—Leverage greatly reduced after data acceptance

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Restrictive Legends

Required on all non-commercial deliverables Authorized Legends:

Copyright Notice GPR/SBIR Data Rights Limited/Restricted Special License

Nonconforming: Unauthorized legends that do not comply with data rights clause may not be used. Per clause, contractor is notified and given 60 days to correct.

Unjustified: Legends that do not accurately depict data rights. Per clause, Govt can challenge; markings remain in place until challenge resolved

Unmarked: Presume unlimited

DFARS 252.227-7013(f)

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Best Practices

Working data rights issues up front leads to maximum effectiveness

Teams must work together, but every member must be responsible for their own function

Ensure data assertions/contract attachments are clear and precise; clarify when necessary

Ensure legal reviews non-standard rights; non-standard rights must be fully captured in the contract

Use ACO to get history on funding if no other source of information

Ensure inspector proactively monitors deliverable data and software markings

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CASE STUDY

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Background

In assertions, contractor identified three items to be provided with limited data rights

Acq team determined that Govt Purpose Rights were needed

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Assertions

Contractor asserted all three items were developed with internal funds

Description was vague, but nobody questioned at first

Upon further review, it became apparent assertions were not specific enough to identify items

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Clarification

Govt requested clarification The contractor’s response still didn’t specify what

data they actually developed at private expense The response opened more questions about

funding of previous research The tech team’s literature search revealed the

Govt paid for the initial research

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Negotiated Settlement

Govt relied on funding history data research Based on research, Govt and contractor

negotiated GPR instead of the limited rights proposed

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Lessons Learned

Determine data rights needs Remember--An assertion is only an assertion

Govt acq team must evaluate, validate, and negotiate

Understand specifically what data is being asserted with limitations and what the basis is for the assertion

Literature searches aren’t just file stuffers Research options and talk to PK and Legal Resolve data rights issues sooner rather than later

CONCLUSION

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Summary

Data rights can differ significantly between civilian and DOD agencies

Data rights decisions can have far-reaching impacts on lifecycle costs and corporate intellectual property rights

Work with your acq team to find the right data rights solution—early & up front

Consider the scope of rights granted to the Government and other contractors

Properly markproprietary technical data

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QUESTIONS?

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Backup

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Contract Provision & Clauses

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Provision

DFARS 252.227-7017 Identification & Assertion of Use, Release, or Disclosure Restrictions (JUN 1995) Use when non-commercial tech data or software

required Contractor must certify to this provision in

Section K List all tech data with less-than-unlimited rights or

respond “negative” Includes assertions on behalf of subcontractors

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Contract Clauses

DFARS 252.227-7013 Rights in Technical Data—Noncommercial Items (NOV 1995)

DFARS 252.227-7014 Rights in Noncommercial Computer Software & Noncommercial Computer Software Documentation (JUN 1995)

DFARS 252.227-7015 Technical Data—Commercial Items (NOV 1995)

DFARS 252.227-7018 Rights in Noncommercial Technical Data—Computer Software—Small Business Innovation Research (SBIR) Program (JUN 1995)

Others in the DFARS 227 series as applicable

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Contract Clauses (cont)

252.227-7019 Validation of Asserted Restrictions--Computer Software

 252.227-7037  Validation of Restrictive Markings on Technical Data

The validation clauses are used in combination with the other data rights clauses

Justification: The contractor is responsible for maintaining records sufficient to justify the validity of its markings that impose restrictions on the Govt’s data rights Contractor shall be prepared to furnish a written

justification for restrictive markings Exception: Contracts for commercial items

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FAR Limited Rights

Limited Rights Notice (Dec 2007)

(a) These data are submitted with limited rights under Government Contract No. _____ (and subcontract ______, if appropriate). These data may be reproduced and used by the Government with the express limitation that they will not, without written permission of the Contractor, be used for purposes of manufacture nor disclosed outside the Government; except that the Government may disclose these data outside the Government for the following purposes, if any; provided that the Government makes such disclosure subject to prohibition against further use and disclosure: [Agencies may list additional purposes as set forth in 27.404-2(c)(1) or if none, so state.]

(b) This notice shall be marked on any reproduction of these data, in whole or in part.

Limited Rights Notice (52.227-14 Alt. II)

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FAR Restricted Rights

Restricted Rights Notice (Dec 2007)

(a) This computer software is submitted with restricted rights under Government Contract No. _______ (and subcontract ________, if appropriate). It may not be used, reproduced, or disclosed by the Government except as provided in paragraph (b) of this notice or as otherwise expressly stated in the contract.

(b) This computer software may be—

(1) Used or copied for use with the computer(s) for which it was acquired, including use at any Government installation to which the computer(s) may be transferred;

(2) Used or copied for use with a backup computer if any computer for which it was acquired is inoperative;

(3) Reproduced for safekeeping (archives) or backup purposes;

(4) Modified, adapted, or combined with other computer software, provided that the modified, adapted, or combined portions of the derivative software incorporating any of the delivered, restricted computer software shall be subject to the same restricted rights;

(5) Disclosed to and reproduced for use by support service Contractors or their subcontractors in accordance with paragraphs (b)(1) through (4) of this notice; and

(6) Used or copied for use with a replacement computer.

(c) Notwithstanding the foregoing, if this computer software is copyrighted computer software, it is licensed to the Government with the minimum rights set forth in paragraph (b) of this notice.

(d) Any other rights or limitations regarding the use, duplication, or disclosure of this computer software are to be expressly stated in, or incorporated in, the contract.

(e) This notice shall be marked on any reproduction of this computer software, in whole or in part.

Restricted Rights Notice (52.227-14 Alt. III)

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FAR Restricted Rights

Restricted Rights Notice Short Form (Jun 1987)

Use, reproduction, or disclosure is subject to restrictions set forth in Contract No. _______ (and subcontract, if appropriate) with ________ (name of Contractor and subcontractor).

Restricted Rights Notice (52.227-14 Alt. III) (Short Form)

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