Jeff Hall

Sunday, January 16`, 2004 Re: Proposed enrollment and disciplinary rules

Subject: Re: Proposed enrollment and disciplinary rules
Date: Sun, 18 Jan 2004 12:51:12 +0000
From: Jeff Hall <ieffhallftot.net>


Sirs:

I have been a patent practioner in the PTO for over 16 years I am very shocked at some of the proposed enrollment and disciplinary rules proposed and respectfully strongly reccommned that they are not implemented.

For example, the new annual fee proposal--although it is unclear to me, why the patent office which is a money making operation needs to burden
its practitioners, my main concern is how the rules appear to be set up.

It is SHOCKING that failure to pay in a-short 3 month period would lead-- to administrative suspension, where the practitioner may not conduct any business with the office. This would expose patent pracatiioners to great liability. Why not just have a staged set of fees--that if not paid in time, would be doubled over the next six month period-but give a practiioner some time if the fee has not been paid. Suspension from pracatice is a bit absurd--it is especially troublesome since there are often errors ro lost mail etc. In the patent office--are we going to be liable for that!! Please reconsider this and do not implement this proposal!!

Also, as for continuing educaiton, a small amount is fine but all attorneys are already subject to state bar requiements. How much continuing education do we really need--at what cost! Why can't attorneys use their state bar cont. ed. and sumit this to the Patent Office.

The Patent office has been a great place to work with over the past years--please don't impelment a set of awful rules that we not improbve anthing at all.
respectfully ,

Jeff Hall