Sent: Tuesday, November 09, 1999 2:17 PM
Subject: Proposed rule changes
This message is a comment regarding the proposed rule changes specified in the Federal Register Vol. 64, No. 191. My comments reflect those of myself and the other shareholders of the business that I am presidentof. Our comments specifically relate to the proposed changes regarding the relaxing of standards for patent drawings.
The goals of the PTO of reducing processing time of patent applications and improving service to PTO customers are excellent. I fully support changes that result in faster processing, while maintaining highstandards of quality.
Our concern is that relaxing drawing requirements would result in issuance of patents with drawings that may have been understood by the Examiner (who specializes in the art) but that could be difficult for others to understand. According to 181(a), "The applicant for a patentis required to furnish a drawing of his or her invention where necessary for the understanding of the subject matter sought to be patented:" In most cases, clear and precise drawings are absolutely necessary tounderstanding the subject matter. These clear and precise drawings are best ensured by maintaining high standards for drawing requirements.
Relaxing drawing requirements would also rely on subjective analysis, examiner by examiner, of acceptable standards. At least with the present standards, we have a degree of uniformity and high quality thatcan be relied on. The present standards are consistently enforced and ^well understood by competent draftsmen.
Your acceptance of these comments is appreciated.
1411 West Garland, Suite D
Spokane, WA 99205