Internet-Draft IETF Antitrust Guidelines December 2021
Halpern, et al. Expires 10 June 2022 [Page]
Network Working Group
Intended Status:
Best Current Practice
J. M. Halpern, Ed.
B. Biddle
Biddle Law PC
J. Daley
IETF Administration LLC

Antitrust Guidelines for IETF Particiants


This document specifies policy for IETF participants on compliance with antitrust laws and how to reduce antitrust risks in connection with IETF activities.

Status of This Memo

This Internet-Draft is submitted in full conformance with the provisions of BCP 78 and BCP 79.

Internet-Drafts are working documents of the Internet Engineering Task Force (IETF). Note that other groups may also distribute working documents as Internet-Drafts. The list of current Internet-Drafts is at

Internet-Drafts are draft documents valid for a maximum of six months and may be updated, replaced, or obsoleted by other documents at any time. It is inappropriate to use Internet-Drafts as reference material or to cite them other than as "work in progress."

This Internet-Draft will expire on 4 June 2022.

Table of Contents

1. Introduction

Standards development frequently requires collaboration between competitors. Cooperation among competitors can spark concerns about antitrust law or competition law violations (antitrust law and competition law are used here synonymously). Certain actions taken by a company that holds a dominant market position can similarly spark concerns about competition law violations. This document specifies policy for IETF participants about how to reduce antitrust risks in connection with IETF activities.

2. Terminology

The key words "MUST", "MUST NOT", "REQUIRED", "SHALL", "SHALL NOT", "SHOULD", "SHOULD NOT", "RECOMMENDED", "NOT RECOMMENDED", "MAY", and "OPTIONAL" in this document are to be interpreted as described in BCP 14 [RFC2119] [RFC8174] when, and only when, they appear in all capitals, as shown here.

The IETF does not provide legal advice to participants, and instead encourages participants to obtain independent legal advice as needed. IETF participants should always consult with their own counsel when antitrust or competition law-related questions arise.

4. Existing BCPs

Compliance with the BCPs that document the established rules and norms of the IETF facilitates compliance with antitrust law, as the IETF structure and processes are intended to mitigate antitrust risks. As a reminder, participants are already required to comply with the following policies documented in the BCPs:

5. Antitrust Policy

All IETF participants MUST behave lawfully when engaged in IETF activities, including by following applicable antitrust laws. While antitrust laws vary between jurisdictions, IETF participants SHOULD NOT assume that they need only comply with the laws of the jurisdiction they reside in as the laws of multiple jurisdictions may apply. Accordingly IETF participants SHOULD NOT engage in or otherwise support any of the following:

6. Escalation of antitrust-related concerns

Participants SHOULD report potential antitrust concerns in the context of IETF activities through the following channels: IETF Chair (, the IETF LLC executive director (, the IETF legal counsel (, or via the IETF LLC whistleblower service.

7. IANA Considerations

No values are assigned in this document, no registries are created, and there is no action assigned to the IANA by this document.

8. Security Considerations

This document may be considered to document means to avoid risks to the IETF and IETF participants related to antitrust. One may consider those to be security considerations. Other than that, this document introduces no known security aspects to the IETF or IETF participants.

9. Normative References

Bradner, S., "Key words for use in RFCs to Indicate Requirement Levels", BCP 14, RFC 2119, DOI 10.17487/RFC2119, , <>.
Leiba, B., "Ambiguity of Uppercase vs Lowercase in RFC 2119 Key Words", BCP 14, RFC 8174, DOI 10.17487/RFC8174, , <>.
Bradner, S., "The Internet Standards Process -- Revision 3", BCP 9, RFC 2026, .
Dusseault, L. and R. Sparks, "Guidance on Interoperation and Implementation Reports for Advancement to Draft Standard", BCP 9, RFC 5657, .
Housley, R., Crocker, D., and E. Burger, "Reducing the Standards Track to Two Maturity Levels", BCP 9, RFC 6410, .
Resnick, P., "Retirement of the "Internet Official Protocol Standards" Summary Document", BCP 9, RFC 7100, .
Kolkman, O., Bradner, S., and S. Turner, "Characterization of Proposed Standards", BCP 9, RFC 7127, .
Dawkins, S., "Increasing the Number of Area Directors in an IETF Area", BCP 9, RFC 7475, .
Halpern, J., Ed. and E. Rescorla, Ed., "IETF Stream Documents Require IETF Rough Consensus", BCP 9, RFC 8789, .
Bradner, S., "IETF Working Group Guidelines and Procedures", BCP 25, RFC 2418, .
Wasserman, M., "Updates to RFC 2418 Regarding the Management of IETF Mailing Lists", BCP 25, RFC 3934, .
Resnick, P. and A. Farrel, "IETF Anti-Harassment Procedures", BCP 25, RFC 7776, .
Resnick, P. and A. Farrel, "Update to the IETF Anti-Harassment Procedures for the Replacement of the IETF Administrative Oversight Committee (IAOC) with the IETF Administration LLC", BCP 25, RFC 8716, .
Moonesamy, S., Ed., "IETF Guidelines for Conduct", BCP 54, RFC 7154, .
Bradner, S., Ed. and J. Contreras, Ed., "Rights Contributors Provide to the IETF Trust", BCP 78, RFC 5378, .
Bradner, S. and J. Contreras, "Intellectual Property Rights in IETF Technology", BCP 79, RFC 8179, .

10. Informative References

Authors' Addresses

Joel M. Halpern (editor)
P. O. Box 6049
Leesburg, VA 20178
United States of America
Brad Biddle
Biddle Law PC
650 NE Holladay Street, Suite 1600
Portland, OR 97232
United States of America
Jay Daley
IETF Administration LLC
1000 N. West Street, Suite 1200
Wilimington, DE 19801
United States of America