In summer 2014 the IPO consulted on proposed secondary legislation, namely a statutory instrument (SI), to implement the UPC Agreement into UK domestic legislation. The IP Federation responded to that consultation (see Policy Paper 9/14), providing general comments in three key areas, namely (1) Jurisdiction (UK alignment, transitional provisions, IPO Opinions service), (2) Unitary Patent (threats and double patenting), and (3) Infringement Exceptions (specifically software interoperability, Article 27(k) UPCA).