ACTA is basically a re-write of Part III of the TRIPS, which is the part dealing with the enforcement of intellectual property rights. How do Part III of the TRIPS and ACTA compare in terms of the frequency of terms? Using the August 25, 2010 text, which includes in some cases duplication where there are competing versions of the text, the comparison now looks like this:
| Terms | Part III of TRIPS | ACTA |
| All words | 3,001 | 10,683 |
| Shall | 67 | 163 |
| May | 16 | 81 |
| At Least | 3 | 18 |
| Seizure (or variations) | 1 | 12 |
| Destroy | 2 | 5 |
| Liability | 1 | 10 |
| Damages | 3 | 8 |
| Imprisonment | 1 | 2 |
| Criminal | 4 | 21 |
| Aiding and Abetting | 0 | 2 |
| Circumvention or circumventing | 0 | 6 |