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Moatz, Harry
From: bgriedel@...
Sent: Wednesday, February 11, 2004 1:38 PM
To: ethicsrules comments
Subject: practitioner recertification

Attn: Director Moatz, O.E.D.

Dear Director Moatz,

I have a brief commentary below concerning proposed certification of practitioners. I'd like to thank you in advance for considering my comments.

Concerning "options 1-4" listed at http://www.uspto.gov/web/offices/com/strat2l/action/lrlcp5l.htm, my only comments are regarding "option 3."

I think the concept of recertifying agents and attorneys is a good idea, but some of the langauge in option 3 troubles me. I agree with the recertification being a "basic system for assuring confirmation of currency of legal knowledge required of all registered practitioners." But the language, "Registered practitioners could pursue additional currency of legal knowledge confirmation systems addressing more issues in greater detail to obtain additional certification of expertise. Costs for the additional confirmation systems would be borne by the practitioners pursuing the systems..." strikes me as describing a system that is excessive and cumbersome (for both the USPTO and the practitioners).

Sure, provide a uniform, simple system that assures currency of knowledge of practitioners (and charge for it to cover PTO overhead) , but please don't implement a multi?tiered system with added fees and "hurdles" for practitioners to jump in order to "keep up with the Jones's." For example, if there are multiple "levels" of currency certification, how many? How often does one recertify, every year? For which ones? How many tests have to be taken each year? Do you see my point? Please, just stick to the great idea of yearly certification via a single test, whatever the format.

respectfully submitted,
Brian D. Griedel, Ph.D.
Patent Agent
2/11/04