Please include in the paper copy in the looseleaf and in the comments being posted on the web
-----Original Message-----
From: Douglas_B_Farrow@...
Sent: Tuesday, March 09, 2004 12:18 PM
To: ethicsrules comments
Subject: Proposed ethics rules revisions

My initial impression of the proposal is that this is a solution in search of a problem.

All attorneys are governed by the ethics rules in their states. The differences between states are not significant. This leaves only the agents - it would be a simple matter to have the PTO rules dictate that agents shall be governed by the attorney rules for the jurisdiction where they practice As to mandatory CLE, it appears that a large majority of states have it and attorneys registered there are already reporting. For those in states without mandatory CLE (and agents in states with it), there could be a PTO reporting process (it would need much less resource) funded by attorneys/agents in those states not having it mandatory.
This would result in a much simpler system with the public still being protected by existing procedures.

Douglas B. Farrow
Corporate IP Counsel
Graco Inc.
PO Box 1441
Minneapolis, MN 55440-1441 USA
612-623-6769 voice
612-623-6944 fax
dfarrow@...