Moatz, Harry
From: rcrandell@....
Sent: Tuesday, December 16, 2003 4:49 PM
To: ethicsrules comments
Subject: Comments Re Proposed Rules 11.12 and 1.21(a)(7)

Proposed Rule 11.12 would burden 28,000 competent Registered Practitioners because of the alleged transgressions of an insignificant number of Practitioners. Proposed Rule 11.12 should be deleted.

Because Proposed Rule 11.12 and its attendant expense is unnecessary, the annual fee for Registered Practitioners of Proposed Rule 1.21(a)(7) should be omitted or substantially reduced.

Not all Patent Practitioners have a yearly income of $100,000.00. Many earn less. A maximum annual fee of $25.00 should cover administrative expenses of maintaining the Register. .

Before adopting either Proposed Rule, competent studies of the real need for such changes should be made and reported.

Ralph F. Crandell
Registered Patent Attorney
Centennial, Colorado