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IA filed the attached comments in response to the United States Patent and Trademark Office (USPTO) request for comments on the application of secondary trademark infringement liability to e-commerce. IA’s comments point out that while a small percentage of bad actors have used the internet to sell counterfeit goods, internet companies, including IA’s members, are at the forefront of protecting consumers from counterfeits. The experiences of IA’s members demonstrate that existing trademark doctrine strikes the right balance between protecting consumers and brand owners from counterfeit goods, while also allowing the online economy to thrive.