On behalf of its member organizations, Biotechnology Innovation Organization (“BIO”) respectfully submits this Comment in response to the United States Patent and Trademark Office’s (the “Patent Office” or “PTO”) February 13, 2024 Request for Comments. See 89 FR 10043 (the “Guidance”). BIO is the world’s largest trade association representing biotechnology companies, academic institutions, state biotechnology centers, and related organizations across the United States and in more than 30 other nations. BIO members include startup companies developing their first commercial products to multi-national Fortune 500 pharmaceutical corporations. The use of artificial intelligence and machine learning (together: “AI”) tools is becoming increasingly common, though not ubiquitous, among BIO’s member companies, who deploy this technology to assist in drug discovery, clinical trial design, manufacturing process improvements, and a range of other applications. While BIO’s member companies have not yet developed a uniform view on the Office’s Inventorship Guidance, we would like to offer a few high-level comments that we believe reflect prevalent attitudes among BIO’s membership.