OBLON, SPIVAK, MCCLELLEND, MAIER, & NEUSTADT, P.C.
ATTORNEYS AT LAW
FOURTH FLOOR
1755 JEFFERSON DAVIS HIGHWAY
ARLINGTON, VA 22202 U.S.A.
(703) 413-3000
(703) 413-2220 FACSIMILE
OBLONPAT@OBLON.COM
PATENT, TRADEMARK AND COPYRIGHT LAW
AND RELATED FEDERAL AND ITC LITIGATION
November 20, 1998
Stephen Kunin, Esq.
Deputy Assistant Commissioner
for Patent Policy and Projects
United States Patent and Trademark Office
2121 Crystal Drive
Crystal Park 2
Suite 902
Arlington, Virginia 22202
Dear Steve:
Enclosed are the formal comments of Oblon, Spivak, McClelland, Maier & Neustadt on the 21 Topics in the Advanced Notice of Proposed Rulemaking set forth in the October 5 Federal Register.
We appreciate the Patent and Trademark Office's dealing in such an open way with the major users of the Office's services.
The firm's comments speak for themselves, but I wanted to add my personal concern regarding
the proposals imposing limits or requirements on Information Disclosure Statement submissions. The
changes proposed, in our view, would present enormous difficulties and in many cases unresolvable dilemmas for the users of the patent system.
Given your extensive experience and background, I hope that you will rethink the proposals on IDSs and reach a more workable approach. We would of course be pleased to work with in this matter.
Respectfully submitted,
OBLON, SPIVAK, McCLELLAND,
& NEUSTADT, P.C.
Gerald J. Mossinghoff,
Senior Counsel
GJM:lnh
Enclosure
