Pub. L.
No. 105-147, 111 Stat. 2678. The Act also directed the United States
Sentencing Commission to "ensure that the applicable guideline range for
a defendant convicted of a crime against intellectual property . . . is
sufficiently stringent to deter such a crime" and to "ensure that the
guidelines provide for consideration of the retail value and quantity of
the items with respect to which the crime against intellectual property
was committed."* Id.* See also endnote 5, chapter 5, *supra.*
3 In 1994, the Uruguay Round Agreements Act added section 2319A to
title 18 of the *United States Code.* Pub. L. No. 103-465, 108 Stat.
4809, 4974. In 1997, the No Electronic Theft Act amended section 2319A
by redesignating subsections (d) and (e) as subsections (e) and (f),
respectively, and by adding subsection (d). Pub. L. No. 105-147, 111
Stat. 2678. See also endnote 2, *supra*, regarding the United States
Sentencing Commission.
4 In 1948, section 1338, entitled "Patents, copyrights, trade-marks,
and unfair competition," was added to title 28 of the *United States
Code.* Pub. L. No. 773, 62 Stat. 869, 931. In 1970, the title of section
1338 and the text of subsection (b) were amended to insert "plant
variety protection" after "patent.
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