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From:

F rom: VMML u nd@aol. com

Sent: Tuesday, November 30, 1999 12:58 PM

To: regrefo rm @uspto.gov

Subject : Notice of proposed rulemaking.

In response to the Notice of proposed rulemaking, published in the Federal Register on October 4, 1999, I strongly object to the new proposed Rule 105 which appears to be without any reasonable justification. This proposed rule would create a new type of PTO "action" and create an unreasonable burden on Applicants. It would attempt to shift the burden of examination from the Examiner to the Applicant but would not meet the goal of simplification PTO processes, making them more difficult and time-consuming and placing additional burdens on Examiners. It is not only without authority in the Statute, but the examples cited by the PTO would encourage Examiners to make inquiries as to the "manner in which the invention was made" so as to be directly inconsistent with the last sentence of 35 USC 103(a). Attention is invited to the last sentence of 35 USC 6(a) stating that Commissioner may only "establish regulations, not inconsistent with law"

I also have objections to other proposed changes in rules, particularly including changes in procedures for making amendments, which appear to make things much more difficult for applicants , with little if any advantage to the PTO.

However my primary objection is to the new proposed Rule 105.

Van Metre Lund

9220 E. Prairie Rd #410

Evanston, IL 60203-1644 847 674 2407

Fax 847 674 2616

vm m lund@aol.com

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