Sent: Saturday, February 14, 2004 9:40 PM
To: ethicsrules comments
Subject: Comments regarding changes to 37 CFR Parts 1, 2, 10, and 11
I am a registered patent attorney in good standing with the USPTO since 1973 and am in private practice with my own firm since 1997. I am also an inventor/patentee. Previously, I was Director of Technology Law for Advanced Micro Devices, Chief Patent Counsel for Fluke Instruments, Division Counsel for Schlumberger, Patent Attorney for John Deere, and Engineering Manager for Rockwell International.
Section 1.21: Regardless of how small the fees to be paid by registered practitioners, they will be passed on to applicants by both private and inhouse registered practitioners. In addition, additional costs will eventually have to be imposed on applicants since they will also have to pay for the collection, processing, and monitoring of the collection of fees. Further, costs of rule making, consulting, and adjudication activity regarding fees will also have be passed on to applicants.
Withdrawal of the registered practitioner fees proposal is advocated.
Mikio Ishimaru, Esq.
The Law Offices of Mikio Ishimaru
1110 Sunnyvale-Saratoga Rd., Ste. A1
Sunnyvale, CA 94087
Tel: (408) 738-0592
Fax: (408) 738-0881