Blynn Shideler

Page 1 of 1

Moatz, Harry

From: Blynn@...
Sent: Friday, December 19, 2003 12:55 PM
To: ethicsrules comments
Subject: Proposed CLE Requirements

The office notes that "The ethics rules have not compelled practitioners to promptly become and remain familiar with changes to patent application practices and procedures." The office further notes that individual states CLE requirements are similarly in?effective at requiring practitioners to gain the knowledge of the new PTO procedures.

The office fails to suggest how mandatory CLE attendance will further compel practitioners to become and remain familiar with changes to patent application practice. "Attendance" and "Education" are not synonyms. Practitioners who are now not "promptly becom[ing] and remain[ing] familiar with changes to patent application practices and procedures", will not do so merely by attending a mandatory CLE.

This PTO CLE proposal is merely creating a further administrative cost for the Patent Office that will, ultimately, be passed on to the patentees.

An alternative suggestion is to make sure that the petition fees associated with those Practitioners who fail to "promptly become and remain familiar with changes to patent application practices and procedures" reflect the time and expense the office spends with such petitions. Regardless, a further administrative layer in the PTO is hardly the answer.

Blynn Shideler
The BLK Law Group

12/22/03