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Christopher L. Parmelee

Moatz, Harry

From: clp@...
Sent: Monday, February 09, 2004 6:26 PM
To: ethicsrules comments
Subject: Comments on Proposed Ethics Rules

Mr. Harry I. Moatz
U.S. Patent and Trademark Office
P.O. Box 1450
Alexandria, Virginia 22313?1450

Re: Comments on Proposed Ethics Rules

Dear Mr. Moats:

I write to oppose adoption of the proposed rules published December 12, 2003, at Federal Register Vol. 68, No. 239. Such rules, as currently proposed, impose an undue burden on attorneys and agents who practice before the PTO. Further the proposed rules unnecessarily duplicate existing state rules and procedures governing attorneys.

For example, lawyers in Ohio such as myself are already required to obtain at least 24 hours of CLE instruction every two years. Courses which qualify for credit must be approved by the Ohio Supreme Court. However, under the PTO's proposed rules, there is no requirement that the CLE mandated by the PTO must also qualify for credit under Ohio's or any other State's mandatory CLE requirements. Thus, the PTO mandated CLE requirements may be in addition to state CLE requirements, resulting in an undue burden on practitioners.

In addition, the proposed rules materially differ from the Code of Professional Responsibility which currently applies to attorneys in the State of Ohio. These proposed rules may subject attorneys to potentially inconsistent requirements for attorneys in Ohio.

In addition, although the $100 annual fee may not be unreasonably high, the PTO has failed to justify the need for such a fee. The proposed PTO budget appropriation should put an end to the diversion of PTO fee revenue to other federal programs. Putting an end to the diversion of fee revenue would eliminate the need for this additional fee.

I also oppose the adoption of the proposed rules because inadequate time was given for study and analysis. Sixty days for comments is an unreasonably short amount of time to properly consider all of the implications of the massive amount of proposed rule changes.

For the above reasons, I respectfully oppose the adoption of these proposed rules.


Christopher L. Parmelee
Reg. No. 42, 980
Walker & Jocke LPA
231 South Broadway
Medina, OH 44256


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