An Approach to Reporting Counterfeit Part Findings to Law Enforcement

Two articles published recently in Law360 discussed the reporting of counterfeit parts the DOD Inspector General. …

DOD Pushes Contractors to Keep Reporting Counterfeits to IG” – Part II of an interview with Randy Stone, DOD Deputy Inspector General (Law360, 30 Sep 2014)

You Don’t Have To Report Counterfeits to DOD IG” (Law360, 9 Oct 2014)

The subject of reporting counterfeit part discoveries to law enforcement and other government agencies has been a frequent discussion among government and industry stake holders for the better part of a decade.

Recently, this topic has been discussed at public meetings hosted by the National Intellectual Property Rights Coordination Center (IPR Center), and in a public meeting concerning a rule making for “Expanded Reporting of Non-conforming Items”. [1] During the 9 April 2014 Counterfeit Microelectronics Working Group meeting, IPR Center representatives from several agencies encouraged industry to use the IPR Center as the “one stop shop” for reporting counterfeits to law enforcement. Industry representatives promoted this concept in comments to the proposed rule under FAR Case 2013–002, “Expanded Reporting of Non-conforming Items”. [2]

The IPR Center could be formally established as the focal point for notification to law enforcement. The Government Industry Data Exchange Program (GIDEP) could be used as the central point for notification and the vehicle for dissemination to US Government agencies. The IPR Center presently uses GIDEP as a source of information concerning the discovery of counterfeit parts. In his interview with Law360, Mr. Stone confirmed that DOD IG coordinates with GIDEP. Several DOD investigative and law enforcement organizations are among the extensive list of the IPR Center’s partnering agencies. [3]

Rather than requiring (or expecting) contractors to do duplicative reporting, one report submitted to GIDEP would be immediately available to thousands of its members, including law enforcement organizations and the IPR Center.

Henry Livingston


[1] FAR Case 2013–002 [Docket No. 2013–0002; Sequence No. 1 (06/10/2014)]

[2] Comments to Federal Acquisition Regulation; Expanded Reporting of Nonconforming Items (FAR Case 2013-002), (accessed 9 Oct 2014)

[3] About the IPR Center, (accessed 9 Oct 2014)

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2 thoughts on “An Approach to Reporting Counterfeit Part Findings to Law Enforcement

  1. […] posted this on his blog (counterfeitparts.wordpress.com) concerning counterfeit parts reporting. This article is worth a read, as is the entirety of that […]

  2. […] posted this on his blog (counterfeitparts.wordpress.com) concerning counterfeit parts reporting. This article is worth a read, as is the entirety of that […]

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