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From:

From: lslerdraft@aol .corn

Sent: Thursday, December 09, 1999 8:36 PM

To: regreform@uspto.gov

Subject: PTO-948 Reform

A picture is supposed to be worth a thousand words. Today, the "pictures" that complement a patent’s words are.

Tomorrow, the pictures that result from the PTO’s proposed relaxing of drafting standards will be worth maybe a few hundred.

Today, the PTO-948 form, with its "new dwgs reqd" imprimatur, elicits quality and clarity of illustration. Tomorrow, the new "streamlined" PTO-948 may hasten issuance of a patent, but understanding the patent may take longer. A drawing that isn’t clear leaves the mind unclear. The mind of the lawyer who prosecutes it, the PTO drafter who judges it, the company attempting to secure rights to it.

In remarks solicited by the PTO prior to their proposing drafting changes, several respondents indicated that the PCT drafting standards, which they considered low, should be brought up to US standards, which, at the present anyhow, are high. That makes sense. The US, from where it sits atop the world of technology, should indeed be setting the worldÂ’s tech standards. Ever higher, never lower. That the PTO would opt for the latter was also found ironic by my fellow patent illustrators, Peter Cotsis and Stan Lebovic, in their eloquent and thought-provoking article protesting the PTO rule changes in the December IP Today. "Such changes," they wrote, "will, at best, needlessly burden attorneys and patent examiners. At worst, the result will be thousands of patents with substandard drawings, lacking in the clarity needed to make them comprehensible."

I couldn’t agree more.

As affected as we patent illustrators may be by any reduction of drafting standards, IP attorneys will likely suffer, too. We are few. You are many. Would you consider lifting a placard of protest with us?

Very truly yours,

Saul Isler

Isler Patent Drafting

179 McNear Drive

San Rafael, CA 94901

E: islerdraft@aol.com

T: 415-456-4591

F: 415-456-4592

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