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Gregory W. Moravan

Moatz, Harry

From: Moatz, Harry
Sent: Wednesday, December 24, 2003 8:19 AM
To: ethicsrules comments
Subject: FW: Opposition To Recertifying Patent Attorneys


---- Original Message----
From: gmoravan@...
Sent: Tuesday, December 23, 2003 6:03 PM
To: Quinn, Brigid
Subject: Opposition To Recertifying Patent Attorneys

Dear USPTO,

I am opposed to the proposed recertification rules for a number of reasons:

1. No data in support of the proposed rule: Where is the data indicating that the patent bar is so incompetent that they need periodic recertification? If there is no such data, then the proposed rule is without basis in the facts.

2. No data showing the present ethical rules are insufficient to protect clients who are not compentantly served by the patent bar. Where is the data showing that the present ethical rules are not sufficient to protect clients from incompetent patent attorneys? If there is no such data then the proposed rule is without basis in the facts on this basis also.

3. Every day is already a continuing legal education day. As a practicing patent attorney for over 25 years, it has been my almost daily experience that I have to review the patent statutes, rules, case law, treatises, and the MPEP in order to solve the patent problems that cross my desk on an almost daily basis. Since I already am doing my own CLE on an almost daily basis, the new re?certification rule is an unnecessary redundancy.


4. No local patent cle courses. As a west coast attorney practicing in a smaller town, it would not be possible for me to obtain patent cle courses at a reasonable cost in time and money.

Please. This proposed rule, which comes up every 10 years or so, is still a very bad idea. Since the present system has not been demonstrated by the USPTO to be broken, then it clearly does not need to be fixed.

1 /6/04


Page 2 of 2


Sincerely,

Gregory W. Moravan 28,741
1/6/04

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