(Telecompaper) Sierra Wireless has submitted a complaint with the European Commission (EC) against Nokia for anti-competitive behaviour and a request for the US Federal Trade Commission (FTC) to start a formal investigation. The EC complaint says Nokia is discriminating against Sierra Wireless and abusing its dominant position as a GSM and 3G standard essential patent (SEP) holder. Sierra Wireless alleges that Nokia applies widely different, and therefore unfair, royalty rates for the same SEPs to make identical GSM wireless modules, that Nokia is imposing unfavourable and unreasonable royalty terms that put Sierra Wireless at a competitive disadvantage, and that Nokia has refused to license 3G SEPs for wireless modules in spite of its obligation and repeated requests from Sierra Wireless to do so. Sierra Wireless believes that Nokia is in breach of Article 102 of the Treaty on the Functioning of the European Union and Nokia's obligation to grant SEP licenses on fair, reasonable and non-discriminatory terms (FRAND) as required by the European Technology Standards Institute (ETSI).