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Wallace G

5726 Clarence Ave. Voice 202.236.3707 Alexandria, VA 22311-1008 FAX 703.931.6037

December 1, 1999

Bob Spar @ FAX 703.308.6916 (1-page only) Director, Special Progarms Law Office

Dear Bob,

Thank you for your presentation yesterday at the DC Bar luncheon at the "Top of the Town" in Arlington. This FAX is a comment on the paragraph-by-paragraph numbering system in proposed Rule 1.52. I ask that you only consider the below-mentioned concern; there is not need to acknowledge receipt of this FAX or send any kind of reply/response.

The proposed paragraph-by-paragraph numbering system should not be a problem for practitioners', the system is consistent with current concepts used in desktop publishing software (i.e., in which in a defined group of words is referred to and manipulated as a "frame" or "block").

While I have not read the new rules in great detail, I have one comment as to the paragraph-by-paragraph numbering system. As I read proposed rule 52, it appears that titles and section headings are not to be assigned a paragraph number. I am concerned as to how section headings will be deleted, amended, or inserted between the numbered paragraphs.

As you know, patent applications prepared overseas often have missing, misplaced, or wrongly-worded sections headings. For example, what protocol would be used to insert a new section heading between two existing paragraphs, delete a section heading, and/or change the wording/spelling of an existing section heading? As I see it, the only way an existing section heading could be deleted or amended would be by identifying the section heading by page/line number and requesting the deletion or amendment.

United States Patent and Trademark Office
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