On July 10, 2019, the Department of Commerce (DOC) issued a request in the Federal Register seeking comments from various stakeholders on the state of counterfeit and pirated goods trafficking through online third-party marketplaces and recommendations for curbing the trafficking in such counterfeit and pirated goods.

3PM Solutions was invited to respond to the DOC request and today we submitted our comments.

Our comments highlighted a broad range of issues related to the counterfeit problem on online marketplaces, but specifically emphasized the role of technology in abating trafficking in counterfeit goods:

Reducing counterfeits on online marketplaces will require advancements in technologies for both the physical and digital realms.

3PM has extensive experience building, using, and deploying databases, image recognition, machine learning, natural language processing, neural networks and other forms of artificial intelligence to detect counterfeits at scale.

These digital capabilities matter for two reasons. First, as some stakeholders to the counterfeit problem have previously noted, they do not have the resources to look, nor enforce, everywhere. We do. In fact, we were purpose-built to detect counterfeit across all web properties and we deploy the aforementioned technologies to not only automate detection, but also to improve detection accuracy over time. Second, while certain marketplace operators are deploying the same technologies to detect potential counterfeit goods and prevent them from ever being listed, these marketplace operators are only drawing on their own, much smaller, data pool. While this can be effective in reducing counterfeit at the local level (i.e., that particular marketplace), it simply pushes the counterfeit elsewhere. 3PM takes a global approach, both in the data we collect and the recommendations that our products surface to our clients, so that reporting counterfeit on, for example, Amazon, doesn’t simply push that counterfeit listing to Walmart.

The responses to the (DOC) request will be shared with interagency teams, and specifically the Department of Homeland Security (DHS), for use in preparing a report for the President as directed by the April 3, 2019 Presidential Memorandum on “Combating Trafficking in Counterfeit and Pirated Goods” (Presidential Memorandum).

All stakeholder comments can be viewed on the Regulations.gov website.