On November 30, 2011, the European Commission (EC) published its communication and proposals on Horizon 2020 (H2020). LERU believes that a number of aspects mentioned in the EC’s proposal for H2020 are noteworthy and deserve strong support. However, LERU does have some concerns regarding the proposals for H2020, e.g. some of the IPR definitions and terms in the proposed regulation are too vague or seem to put universities at a disadvantage compared to industrial participants. Throughout the paper, LERU discusses its concerns and proposes alterations.