Major jurisdictions recognize the importance of standards and the need for strong protection and enforcement of IPRs to drive innovation, including the EU (in The International Digital Strategy for the European Union, Competitiveness Compass and recent European Parliament resolution on European technological sovereignty and digital infrastructure), China, and, the U.S. through its standard-essential patent (SEP) working group (December 30, 2025 ip fray article) and “Winning the 6G Race” memorandum (December 19, 2025 Presidential Memoranda).
“Global policymakers recognize that FRAND licensing is a motor of innovation which delivers huge economic and social benefits,” Nokia’s Head of IP Policy & Advocacy, Collette Rawnsley, tells ip fray in an exclusive interview.
There is clearly a geopolitical aspect to standards – they are considered both strategically and economically important, Ms. Rawnsley says. Cellular and other standardized technologies are playing an increasingly important role in new and emerging areas and use-cases – from automotive, to IoT, to security and defense applications, to consumer electronics, gaming and video services.
“There is an increasing desire for technological leadership and strategic autonomy from all key jurisdictions,” she adds.
Ms. Rawnsley has headed up global IP Policy & Advocacy at Nokia since May 2022 (after joining the company as director of European IP Policy & Advocacy in January 2021). Prior to that, she held several roles in the UK government’s legal department, notably she was Senior Référendaire at the UK’s Competition Appeal Tribunal, and in private practice (including at Howrey, Shearman & Sterling (now A&O Shearman), and Wiggin).
She recently sat down with ip fray to discuss her team’s proactive and reactive engagement with key stakeholders (policy-makers, regulators, and industry) on the importance of emerging jurisdictions on the global SEP stage, ongoing policy initiatives, the “premature” inclusion of licensing negotiation groups in the European Commission’s draft revised technology transfer guidelines (TTGs), and interim license declarations.
Ms. Rawnsley has had an extremely varied and successful career.
She was involved in early cases involving SEPs, such as the European Commission’s investigation into Samsung, and advised clients, including Nokia, on the implications of cases such as the CJEU’s seminal decision in Huawei v. ZTE.
She also told ip fray about her involvement in the prominent Football Association Premier League case (known as Murphy in the UK) concerning cross-border access to pay-TV content, and the referral to the Court of Justice of the European Union (CJEU), which she said raises many interesting and challenging procedural and legal questions. She subsequently advised on the related competition investigation, e-commerce sector inquiry, and legislative initiatives, including legislation on portability and geo-blocking.
Since joining Nokia at the beginning of 2021, Ms. Rawnsley has successfully taken the lead on a number of key projects, including engagement on the proposed SEP Regulation. Commenting on the dispute with Daimler, which the parties eventually settled with a licensing agreement (June 1, 2021 Nokia press release), she notes that “this was a good commercial outcome, but also laid down some general principles for licensing in the automotive sector”.
But what Ms. Rawnsley has enjoyed doing the most at Nokia is working closely with her colleagues in the company’s licensing, litigation, and communications teams and building out her IP Policy and Advocacy unit. “We are a relatively small team, but we are global in our outlook and are taking a proactive approach to our engagement, which is really important in newer emerging jurisdictions that are trying to get to understand and play an important role in the SEP ecosystem,” she says.
Emerging jurisdictions also featured in a discussion involving Nokia’s Head of Global Litigation and Disputes, Clemens Heusch, at the Patent Litigation Europe Summit last month (January 21, 2026 ip fray article), during which he emphasized the importance of such venues in global SEP enforcement strategies.
Pointing to a case in which Ericsson is suing Chinese smartphone supplier Transsion in the UPC, as well as Brazil, India, Indonesia, Colombia, and – for the first time – Morocco and Nigeria (November 14, 2025 ip fray article), Mr. Heusch noted that while it is becoming impossible to ignore such jurisdictions, someone always has to be the first to try.
“So the enforcement team needs a crystal ball to see into the future – and a lot of it is guessing work,” he said.
Ms. Rawnsley echoes her colleague, noting that while the Unified Patent Court (UPC) and courts in Germany continue to be important venues for SEPs, if an implementer doesn’t have significant sales in these jurisdictions/Europe, then it may not bring an unwilling licensee or an implementer to the table.
One way her team helps Nokia with this specific area is by engaging proactively with institutional stakeholders in emerging markets, including the industry (representatives/players), policy-makers, regulators, and courts, to explain the importance of IP protection and enforcement in incentivizing investment in R&D for future technologies and the virtuous circle of innovation.
A busy 2025
What else kept Ms. Rawnsley’s team busy in 2025? She broke down some of the unit’s key activities, which include:
- The EU’s proposed SEP regulation (withdrawn last year: February 11, 2025 ip fray article): There were a lot of diverging views amongst Member States and stakeholders internationally, which gave her team the opportunity to engage with some new stakeholders, as well as existing ones, to help them understand the global innovation ecosystem. She noted that it was very important that Nokia’s voice was heard, as there are far more implementers of standardized technologies than there are those contributing to open standards, and the company is both. “So it’s really important to ensure that regulators get a balanced perspective and have a clear understanding of what is at stake,” she says.
- China: Ms. Rawnsley commented on the changing role that China is playing in the SEP ecosystem and the keen interest that it has taken in SEP licensing. She has been spearheading Nokia’s proactive engagement in China, meeting with policy-makers and authorities as well as her counterparts in industry and speaking at several high-profile events in the region. She explains that “considering the virtuous cycle of innovation and the importance of global standards, ensuring a system that benefits all companies – whether they hold standard essential patents, implement standardized technologies, or do both, like Nokia – is vital. It should also reflect the global nature of standards and of FRAND licensing.
- The UK IPO SEP consultation: Nokia supports the UKIPO and its evidence-based approach to decision-making, including key data points and facts in its submission. Her team was also actively involved in the UK’s SEPs Resource Hub, a tool for industry, in particular SMEs, to understand and navigate the SEPs ecosystem.
- Supporting Nokia’s litigation: Nokia was involved in several high-profile disputes last year, including a case against Acer and Asus in which the EWHC held in December that a FRAND dispute should be resolved in the UK (December 18, 2025 ip fray article). The company’s stance is that no court in any jurisdiction should set a global FRAND rate unless both parties consent.
Both the EWHC and the England and Wales Court of Appeal (EWCA) have addressed interim license declarations (February 5, 2026 ip fray article), but the UK Supreme Court is yet to issue its say. While it would be interesting to find out its opinion, this is something that would have to come out of a case, and appeals are both costly and time-consuming, Ms. Rawnsley notes. “But the case law may continue to develop in the UK and elsewhere,” she adds.
Technology transfer review risks “conflating” what is needed for patent pool transparency
So what else will the future hold? In 2026, there are a number of upcoming deadlines, ongoing cases, and in-the-works policy initiatives that could drastically change the SEP licensing landscape. Among them is the European Commission’s draft revised TTGs.
Some of the proposed changes, Ms. Rawnsley notes, could make it more challenging to form pools, as well as place a burden on existing pools. This includes a “transparency” requirement, which would require pool administrators to publish patent lists. Some already do this, but each pool operates a different business model, she says, adding:
“There is a risk of conflating what is needed to give transparency as opposed to going down a very prescriptive route, which does not reflect appropriately the dynamic nature of the standardized technologies licensed.”
For her, “the bigger risk is that the proposed revisions to the TTGs will put additional burdens on SEP holders and pool administrators, making them more expensive to run, and therefore having cost implications for licensees, too.”
Nokia also submitted detailed comments on the guidelines’ reference to LNGs, which Ms. Rawnsley thinks may be “premature” given the lack of practical experience of LNGs in operation.
The first comfort letter involving patent pools was published more than a decade before pools were included in the TTGs for the first time in 2014, so there was a lot of experience with them in practise. Meanwhile, the European Commission’s first ‘comfort letter’ regarding an automotive LNG (ALNG) was published last year (July 9, 2025 ip fray article). “So what we have is little, if any, experience of LNGs in order to assess them – the ALNG has not yet begun to operate,” she says.
“There is more dialogue to be had around this, especially in the light of the concerns that have been raised by other competition authorities, including the Antitrust Division of the United States Department of Justice (both under the current Administration and the previous one), about LNGs,” she explains. “What they seem to be suggesting is that an LNG may be a per se violation of antitrust law,” she says.
“It would be good if the European Commission were to engage with its international counterparts to understand what the concerns are. Because when the LNG comfort letter was published, there hadn’t been widespread consultation with industry – even as a large SEP holder with a proven track record of licensing to the automotive industry (including China: January 20, 2026 ip fray article), we were not asked to provide any input.”
Another key upcoming development is the launch of the UPC’s Patent Mediation and Arbitration Centre (PMAC), which will be holding its Inauguration Ceremony in June. While it will take some time to develop, just like any new body or institution, Ms. Rawnsley is positive that it will be an important forum, including for matters involving other jurisdictions outside the UPC’s signatory states.
Less reform, more open dialogue
Nokia has been able to focus on new verticals since the successful completion of its smartphone renewals in 2024, including in the areas of auto, IoT, and video services. Ms. Rawnsley strongly believes patent licensing works:
“The evidence speaks for itself.”
More than 95% of deals are concluded amicably between willing parties, and where disagreements arise, there is alternative dispute resolution or, when necessary, litigation.
According to Ms. Rawnsley, “no system is perfect”, but overall, the current SEP licensing framework has served the world “extremely well”. She believes it has supported massive technology deployment, continuous innovation, and global collaboration, particularly in cellular connectivity. And, she emphasizes, with the debate around SEP licensing and litigation, it is important that “we do not lose sight of the successes that have been achieved”. The companies that participate in this ecosystem are generally very sophisticated and tend to reach negotiated outcomes, she adds.
The IP Policy and Advocacy head notes that there’s been a lot of discussion around SMEs being scared of litigation – but “we haven’t seen evidence of this”. One way that Nokia is ensuring that SMEs continue to only gain from SEPs is through its support of the World Intellectual Property Organization’s mediation pledge (which it was among the first to sign, together with Ericsson, Qualcomm, Sisvel, and Huawei: November 21, 2025 ip fray article). ZTE has recently also joined the pledge.
But above all, to help stakeholders across the ecosystem, Ms. Rawnsley believes it is really important for everyone to engage in constructive dialogue.
There has been a lot of focus on lobbying for regulatory reform, or pushing back against that proposed reform, when actually it would be good to have a more constructive and open dialogue, she says. One of the biggest challenges regarding the proposed SEP Regulation, according to Ms. Rawnsley, is that there was not as much engagement with industry, especially European companies contributing to global standards, as she would have liked:
“I can only hope that the institutions in Europe and indeed around the globe continue to have a constructive dialogue with industry because we are the ones that are trying to make things work on a day-to-day basis.”