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>
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.