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efforts of SSOs to set clearer rules at the outset of negotiations are fears that the FTC will invalidate the product of such negotiations as anticompetitive restraints on trade. This Note makes three arguments: (1) the D.C. Circuit's decision is inconsistent with precedent and could cripple the standard setting process by preventing punishment of parties that purposely deceive SSOs; (2) SSOs should require royalty commitments from their members at the outset of the standard-setting process,doi:10.15779/z386m50 fatcat:yljy4tm4crcdhajlxeidfim2gq