There is potential uncertainty as to the scope of “CRS Services IPR” and “RECCo Services IPR” because they are defined by reference to Clause 13 of the main body of the Code. It is proposed that these definitions should instead be defined in Schedule 1 (Interpretations and Definitions) to the Code, which would have the added benefit of future-proofing the definitions against prospective amendments to the Code main body. Also, “CRS Services IPR” and “RECCo Services IPR” should cover only the IPR which the CRS Provider or RECCo respectively owns or otherwise has the right to license. This will avoid risk that the licences granted under Clauses 13.7 and 13.16 exceed what the CRS Provider and RECCo respectively should be responsible for or are capable of doing. Furthermore, Clauses 13.12(b) and 13.13 should explicitly acknowledge the parts of the CRS solution that are provided under Crown copyright, commercially available off-the-shelf software or other products generally available in the market and do not need to be licensed by DCC in the situations described in these Clauses. The CRS Services IPR provisions should apply only as between the CRS Provider and CSS Users (and not REC Service Users more broadly), namely each organisation which is Qualified to use the CSS, together with each Switching Data Service Provider (other than the CSS Provider) the categories of which are set out in the Central Switching Service Schedule. In respect of “Services Data” defined in Clause 13.18, there is a risk that seeking to specify ownership of IPR in data or datasets will conflict with ownership of the same IPR under other regulatory or contractual arrangements. There is also a technical question as to whether any IPR actually subsist in the data or dataset at all (a piece of data itself not being an IPR). In view of these concerns, there is a question as to whether Clause 13.19 is actually necessary or creates potential ambiguity and confusion over ownership of IPR between numerous industry stakeholders. In turn, this risks ambiguity in Clause 13.20 as to whether the relevant stakeholder can grant the required licences as a matter of fact and the indemnity in Clause 13.21. As a consequence, it is proposed that Clause 13.20 is amended to state that the relevant Parties grant the licences set out in Clause 13.20 only to the extent that they own any IPR subsisting in the Services Data.