5726 Clarence Ave. Voice 202.236.3707 Alexandria, VA 22311-1008 FAX 703.931.6037 firstname.lastname@example.org
December 1, 1999
Bob Spar @ FAX 703.308.6916 (1-page only) Director, Special Progarms Law Office
Thank you for your presentation yesterday at the DC Bar luncheon at the "Top of the Town" in Arlington. This FAX is a comment on the paragraph-by-paragraph numbering system in proposed Rule 1.52. I ask that you only consider the below-mentioned concern; there is not need to acknowledge receipt of this FAX or send any kind of reply/response.
The proposed paragraph-by-paragraph numbering system should not be a problem for practitioners', the system is consistent with current concepts used in desktop publishing software (i.e., in which in a defined group of words is referred to and manipulated as a "frame" or "block").
While I have not read the new rules in great detail, I have one comment as to the paragraph-by-paragraph numbering system. As I read proposed rule 52, it appears that titles and section headings are not to be assigned a paragraph number. I am concerned as to how section headings will be deleted, amended, or inserted between the numbered paragraphs.
As you know, patent applications prepared overseas often have missing, misplaced, or wrongly-worded sections headings. For example, what protocol would be used to insert a new section heading between two existing paragraphs, delete a section heading, and/or change the wording/spelling of an existing section heading? As I see it, the only way an existing section heading could be deleted or amended would be by identifying the section heading by page/line number and requesting the deletion or amendment.