Robert M. Kunstadt

Date: may 23, 2003
Our file: 1-024 bkl
Your file:

e-mail to Commissioner for Trademarks and Ms. Cheryl L. Black,,

Re: Comments on the Proposed Rules to Implement Madrid
Protocol Legislation - Docket No. 2003-T-010

dear ms. black,

here is our comment on the Proposed Rules to Implement Madrid
Protocol Legislation (Docket No. 2003-T-010).


enc. follows (scroll down)




Re: Comments on the Proposed Rules to Implement Madrid
Protocol Legislation - Docket No. 2003-T-010

Dear Commissioner:

This constitutes the comments of R. Kunstadt, P.C. on the
Proposed Rules to Implement Madrid Protocol Legislation,
Docket No. 2003-T-010 (reported at 65 PTCJ 525, 4/4/03).

R. Kunstadt, P.C. is an intellectual property firm located in
New York, New York. We are active in filing trademarks on
behalf of clients in the pharmaceutical, clothing, computer,
beverage and other industries, in the United States and
foreign countries. These comments represent the opinion of the
firm and the undersigned, but are not presented on behalf of
any clients of the firm.


The proposed Sec. 7.11 of the Proposed Rules (65 PTCJ 543)
which requires an international application to be submitted
through TEAS instead of paper forms is unjustified. This will
result in a de-facto mandatory electronic filing system,
something that should only be considered when reliability and
security issues facing Internet transmission have been
overcome, and when the Trademark Office develops an interface
which is compatible with industry-standard office automation

The Trademark Office should revise its electronic procedures
to interface with industry standard office automation programs
before requiring mandatory electronic filing. The Internet is
not yet sufficiently reliable to make it the only means of
communication with the Trademark Office. The Internet is
plagued by viruses and hackers. Security of transmission via
the Internet cannot be assured by present technology. Reliable
Internet connections cannot even be assured; our connection
went down at the time of the September 11th WTC attacks.

Also, there needs to be a provision in the Proposed Rules to
prevent unauthorized practice of law by foreigners who are not
members of the bar of any state. Since no U.S. attorney or
domestic representative is needed to file an international
application, it may be expected that the temptation to answer
an office action without retaining a U.S. attorney will be
irresistible. The Office should require that any office action
reply of a foreign applicant be filed by a U.S. admitted


These comments were prepared by the undersigned Robert M.
Kunstadt, with the assistance of R. Kunstadt, P.C. staff. I am
a graduate of Yale University and the UCLA School of Law. I
studied intellectual property law under the late Professor Mel
Nimmer at UCLA. I held a post-graduate research fellowship at
the Max Planck Institute for Patent, Copyright and Competition
Law in Munich, Germany from 1975 to 1977. In 1978, I commenced
work as an associate at the New York office of the IP firm
Pennie & Edmonds. I worked at Pennie & Edmonds, in the
capacity of associate and subsequently partner, until 1997. In
1997, I established the present firm, R. Kunstadt, P.C. in
order to leverage the benefits of new technology to provide
prompt and efficient service to intellectual property clients.

Our small law office (total staff of five) has invested over
$20,000 in office automation technology. Our principal office
automation program is PROLAW. PROLAW is a SQL database which
works on the "one-write" principle, as do many relational
databases. When data is entered into the program for any
purpose, it is immediately accessible at the press of a
button, to be reused for any other purpose. For example, when
a trademark application is prepared we do not re-type the
client's name, address, state of incorporation, etc. All that
information resides in the "contacts" module of the database,
and is available for use in the "matters" module for the
preparation of a trademark application. Similarly, the
database fields for international class, goods, client address
of record, etc., are filled in once for an application. The
application form is then automatically generated by PROLAW, at
the push of a button, drawing upon the information resident in
the database.

In the past, trademark applications were prepared using a word
processing program such as WordPerfect. Law firms kept
separate databases, either paper databases or computerized,
which duplicated the information in the trademark
applications. This led to inefficiency, because errors crept
in due to discrepancies between the information typed into the
word-processed trademark application and the information that
had been keyed into the database. Significant staff time was
required to weed out these errors and correct the database.
This adversely impacted upon client service and increased the
cost of trademark legal services to clients, due to the need
to pay personnel to correct the database.

The great advantage of a state-of-the-art office automation
database such as PROLAW is that a managing attorney can be
assured that having once checked the data, it will be
correctly replicated for all purposes throughout the program
and in any application form it generates. This leads to a
great savings of time and consequent savings for our clients.
In particular, using the PROLAW office automation program, we
can be assured that there is a perfect correspondence between
the trademark information contained in our database, and the
information printed on the applications we submit to the
Trademark Office.


The Trademark Office already has a fine system for scanning
trademark application data submitted on a paper form, called a
PRINTEAS form. We set up our PROLAW database to simulate the
PRINTEAS form generated by the Trademark Office web-site.
These forms are very simple. Basically, they consist of a
field name coded within carets, followed by the data for that
field. Information which is not to be scanned by the Office is
separated by a tilde character. A sample of such a form is
attached as Exhibit A.

Because the PRINTEAS form utilizes only ascii characters and
is easily human readable, we had no difficulty setting up our
PROLAW system to automatically insert the data from our
database, into the appropriate coded fields of the PRINTEAS

Our office has had excellent success utilizing these forms for
filing trademark applications and other documents (such as
extensions of time and renewals). We hardly ever get an
inaccurate filing receipt anymore. Before we moved to this
system, almost one half of trademark applications resulted in
inaccurate filing receipts, with consequent need for

We do not know exactly how the Trademark Office processes the
PRINTEAS form. However, we expect it is scanned at the Office,
and then checked by an operator to insure accurate scanning.
However it is done, the process works almost fllwlessly. We
are very happy with the way the Office has been processing our
trademark applications and see no need for improvement in this

Indeed, what we suggest is that if the Office is interested in
reducing the need for manually keying data for trademark
applications, the Office should require that all paper
applications be submitted using the PRINTEAS coded fields.
Anybody can prepare an application using these fields, even
without any sophisticated office automation equipment. Even a
manual typewriter would suffice for this purpose. Therefore,
it would not be any great imposition upon the public for the
Office to require that the PRINTEAS coded fields be
implemented on all trademark applications and other documents.

A PRINTEAS form is easy to process by scanning, similar to an
TEAS application, i.e. as soon as the PRINTEAS form has been
scanned it is in the system. By using a scannable PRINTEAS
form the Trademark Office would get the same benefit as it
seeks with electronic filings (TEAS) since once scanned it
would be in the system and as good as a TEAS. The paper could
then be discarded when in the system. Scanning PRINTEAS forms
has the great advantage for the Trademark Office in that the
forms do not carry viruses and do not allow hackers to access
the PTO database.


The TEAS system has been utilized on a voluntary experimental
basis for the past several years. We understand that many
users of the system are satisfied with its operation. When the
system was first made available, we inspected it and
determined that it was not appropriate for the needs of our
office. Therefore, we have not utilized the system. It would
be incorrect for the Office to rely only upon feedback from
users of the TEAS application indicating that they are
satisfied, since there undoubtedly are a large number of
persons who decided not to use the system because they found
it, upon inspection, to be unsuitable.

The specific TEAS interface used by the Trademark Office,
appears to be designed for an inexperienced trademark
applicant. It is not compatible with industry-standard office
automation programs. Many firms (like ours) which are active
on behalf of a large number of sophisticated clients, have
made significant investments in state-of-the-art office
automation technology. Requiring trademark applications to be
prepared and filed by the present TEAS system, would represent
a technological step backward.

The Trademark Office could consider requiring filing in one of
two ways: either electronically (using the TEAS system); or in
print using a form like that generated by the PRINTEAS system.
The TEAS form can only be filled in word-by-word using a
computer keyboard like a manual typewriter. It is not designed
to take advantage of industry-standard office automation
systems based on relational databases. The PRINTEAS form can
easily be prepared by any user, even with only the most basic
office equipment such as a manual typewriter. We are able to
generate a PRINTEAS trademark application automatically, on a
push of a button, by using our office automation database. The
PRINTEAS system, therefore, is suitable for use both by
unsophisticated users, and by users of advanced office
automation technology.

The TEAS system seems to be designed to facilitate filing of
trademark applications by unsophisticated individual users who
had never filed an application before. It contains a "wizard"
interface to guide an unsophisticated user in filling out the
trademark application form. This system is undoubtedly a
benefit to users of that type, and so should be continued on a
voluntary basis. However, the defect of the TEAS system from
the point of view of our firm, and undoubtedly many other
sophisticated users, is that it has no proper interface to any
industry-standard office automation program. Sophisticated
users do not fill out trademark applications by typing
individual words into blanks, one at a time, the way the TEAS
system requires one to work. Sophisticated users use powerful
databases which generate an application form on the push of a
button. Therefore, to require sophisticated users to file
their applications by means of the TEAS system would
effectively put the trademark profession back by forty years.
Back in the 1960s, the state of the art was to fill out a
trademark application form word-by-word on an IBM electric
typewriter. The TEAS system works the same way. Therefore,
TEAS could not be considered progress in office automation by
any stretch of the imagination.

The TEAS form makes extensive use of HTML coding for page
layout purposes (grids, colors, fonts, etc.) and also to
implement Microsoft-style "controls" such as radio buttons and
pull-down boxes. Hence, it is incompatible with standard
office automation programs. While such programs routinely can
perform a "mail-merge" operation to insert text data into
pre-coded fields (as are found on the Office's PRINTEAS form),
they do not presently have the ability to automatically
manipulate HTML controls such as radio buttons and pull-downs.

While such automation might theoretically be possible by the
creation of a custom Visual Basic interface unique to each
office automation program, to impose on users the burden of
such complex programming activity is unwarranted and indeed
unnecessary. There is no functional need for the Office to
employ an electronic filing system as complexly-coded as
TEAS. The far simpler PRINTEAS codes are already compatible
with standard office automation programs using mail-merge
technology, and have proven themselves in our experience to be
fully functional to achieve the desired purpose of flawless
input to the Office's database. While TEAS has a "glitzier"
interface, we submit that function, not form, should be the
over-riding concern in designing a practical system. A key
functional need which TEAS overlooks is compatibility with
industry-standard office automation programs. PRINTEAS codes,
in contrast, meet that need perfectly.

It would undoubtedly be possible to develop electronic filing
systems that would be compatible with state-of-the-art office
automation systems. Indeed, a very simple such system would
merely require the user to email the ascii text of the
PRINTEAS form to the Trademark Office. The Office could then
electronically input the PRINTEAS form by recognition of the
coded field headers, into the Office's database. Such a system
would be entirely compatible with any office automation system
which can generate a simple ascii text record. To maximize the
potential for compatibility with the diverse office automation
systems being used, we suggest that the Office consider to use
the most "plain vanilla" interface possible: simple ascii text
without HTML formatting codes. In this respect, the PRINTEAS
form would be a perfectly satisfactory model.

One of the reasons given for the TEAS system is that it is
faster to file electronically. This is not correct as one has
to type all the information into the electronic form in TEAS
while with PRINTEAS a word processor can create the file with
the pertinent information by itself. Then one just has to make
minor adjustments on the mark and goods before printing it out
and putting in envelope. This only takes a few minutes since
the PRINTEAS format is already set up while it will take much
longer to file a typical TEAS trademark application since one
has to type the entire application each time one uses the
TEAS. It is therefore not faster to use TEAS online when
compared to PRINTEAS.


Computer World of September 24, 2001, page 1, reported on the
NIMDA worm having infected numerous Internet servers. This
worm is capable of spreading not only by email, but also by
web browsers such as those utilized by the Office's TEAS
system. The worm is capable of installing a "back door" onto
an infected system, leaving the system vulnerable to further
hacker attacks. Standard anti-virus software available at the
time the worm struck in August 2001, failed to keep it from
spreading. Indeed, even the most careful users of anti-virus
software face risks from use of the Internet, since there
always is a lag between the time when a new worm or virus is
detected, and the anti-virus software can be updated. For that
reason, this firm does not permit our network to be connected
directly to the Internet. All Internet communication is
conducted from a separate, standalone terminal. We view this
as a necessary measure to protect the security of valuable
intellectual property information stored on our network.

According to informational mailing received from Cisco Systems
by undersigned, Computer Economics estimated that $2 billion
was the "damage caused by the Code Red Worm, making it the
second costliest security breach ever". The Code Red worm was
one of the most damaging and quickly spreading threats to the
Internet to date. Over the course of just 2 days, over 300,000
hosts were infected - with damages totaling in the hundreds of
millions of dollars. Furthermore, Computer World of June 3,
2002, page 6, discusses how security holes closed part of the
UK Tax Service: "The U.K. government's tax department shut
down an Internet-based self-assessment service because of
security breaches that lead some users see the personal data
of other individuals. The Inland Revenue department said the
problem was caused by flaws in an electronic form use to file
taxes online. The agency was unable to say how long it would
take to fix the service." In the same periodical on page 7,
it is reported that Fidelity Canada had to closes a security
hole in its system; "Toronto-based Fidelity Investments Canada
Ltd. Said it has corrected a problem that allowed an Ottawa
college professor to access static account information
belonging to other customers."

Therefore, it seems inappropriate to require all users of
Trademark Office services, to operate only via the Internet,
upon pain of punitive surcharges. Until such time as better
security can be assured for Internet transactions, the Office
would be forcing users to bear risks which many people do not
wish to incur. Small businesses and small law firms would be
particularly adversely affected because of the high cost for
investment in firewalls and other security measures.

Furthermore, the Internet is not even a reliable means for
communication. It is subject to periodic outages and service
interruptions, not only due to malicious hacker attacks but
also due to simple technical difficulties at Internet service
providers. If we were effectively required to conduct all
business with the Trademark Office only by the Internet, and
if our Internet service provider had an outage or other
technical difficulty, we could be unable to service our
clients. Since often there are critical deadlines which must
be met in order to preserve our clients' trademark rights,
such an unanticipated and uncontrollable technical difficulty
could prejudice our clients' rights. The Office's answer, not
to wait until the last minute, is simply unrealistic. Unlike
the Office, our firm has a service orientation. We are not
here to tell our users (clients) how and when to make their
filings. We are here to serve their needs and follow their
instructions, whether given timely or belatedly.

Indeed, subsequent to the terrorist attack on the World Trade
Center here in New York City, we were not able to get a
connection through Compuserve, our usual Internet service
provider. For the first several days, there was no phone
service at all. Then, we were able to get a connection, but
only by dialing into Compuserve's 800 number.

Given the United States' declared war on terrorism, the
Internet must be viewed as less reliable than ever. We can
expect instances of "cyber-terrorism" which will adversely
impact availability of service on the Internet. While the
Trademark Office itself may not be a specific terrorist
target, terrorist attempts to interfere with commerce in the
United States by "Denial of Service" attacks targeting the
Internet as a whole, would adversely impact on the Trademark
Office's ability to provide service, if the sole means of
communication with the Office were the Internet. Therefore, if
the Office does indeed wish to institute de facto mandatory
e-filing, we recommend that the Internet not be the only means
of electronic access. The Office should maintain a modem bank
permitting direct dialin connection to the Office. A direct
dialin connection is more secure than the public Internet. It
would permit the Office to trace the origin of malicious

A major advantage of the PRINTEAS systems is that it is not
subject to infection by viruses or manipulation by hackers.
Attempts to introduce viruses or to hack the system can be
detected because the PRINTEAS document is easily
human-readable. The Office can see a non-standard PRINTEAS
form containing malicious code, and can decline to scan it.
Our firm has had excellent results over the past several
years, using the PRINTEAS codes. Mistakes by the Office
requiring correction of the filing receipt have been rare.


Suppose one submits a credit card authorization to support an
application over the Internet. There is a lag between the
submission of the authorization, and the receipt of an
acknowledgement that the charge has been duly processed.
During that lag time, many things can go wrong. The Internet
is not a flawless means of communication. Therefore, if any of
the multitude of servers which process the request along the
way, drops or garbles the request, it would not be correctly
received and acknowledged. During that time, the request is in
limbo. If no proper acknowledgment comes back, the user faces
a conundrum. Should the user assume that the request was not
received, so it needs to be re-sent? Or should the user assume
that it will be received in due course, and do nothing? If the
user assumes the request was not received and re-sends it, the
user runs a risk of incurring duplicate charges on his or her
credit card. On the other hand, if the user does nothing, than
the user may never get the desired result.

This conundrum is particularly acute for a law firm, which
assumes the responsibility for making filings on behalf of its
clients. A law firm cannot simply sit back and hope that
things would work out, if no acknowledgement is received. The
law firm must act to meet deadlines, even if this involves the
risk of incurring duplicate charges.

This particular risk does not seem to be mitigated by the
Trademark Office's TEAS system. Suppose a law firm has to file
an extension of time for a statement of use, and the client
gives the instructions only on the last day. The law firm uses
the TEAS system to submit the request. However, at the close
of business no acknowledgment has been received from the
Trademark Office. What should the law firm do? If the law firm
does nothing, it runs the risk that the deadline would be
missed. Therefore, the law firm has no choice but to re-submit
the request. This may result in a duplicate charge upon the
law firm's credit card or deposit account. It could take
months to sort this situation out; if the Office would even
grant a refund, which is not clear under the present system.

The Office takes the position that its system gives an
acknowledgement within a matter of minutes. This is fine, if
it works -- but if Internet communication is disrupted, there
will be no acknowledgement in a matter of minutes, hours or
perhaps even days.

Any system which relies upon electronic payments being made
over an unreliable communications system such as the Internet,
must be created in such a way as to prevent this conundrum
from occurring. One way this can be attempted, is to assign a
tracking number to a transaction at the very start of the
transaction, before any charges are incurred. Given this
tracking number, the user can later inquire into the fate of
the transaction, if at the end of the transaction, no proper
acknowledgment has been received. The Office will have to be
willing to accept these tracking numbers in the same way that
it currently accepts Express Mail receipt numbers, as proof
that the necessary filings were made. Otherwise, law firms
would have no proper way to demonstrate that they fulfilled
their obligation to make timely filings on behalf of their
clients, if communication difficulties and/or other
difficulties at the Internet service provider, on the Internet
itself or at the Trademark Office prevented proper completion
of the transaction in due time.

This is the reason why at present, experienced users rely upon
Express Mail as proof of filing. Given an Express Mail filing
receipt with an Express Mail number and "date in", one can
confidently leave work at the end of the day with assurance
that one's duty to make the necessary timely filing on behalf
of a client has been satisfied, even if the Express Mail
package is later lost in transit. Any system which cannot
provide that assurance, must be considered unacceptable by
properly-informed users of Trademark Office services.


If this mandatory e-filing through TEAS to be implemented, the
Trademark Office should at least exempt submissions by express
mail that include a floppy disc, at no extra charge. This
would clearly serve the purpose of having electronic filings.
There is no great work involved in reading a floppy disc and
submitting a floppy disc would cost applicants a small amount
of money while still giving the Trademark Office the
application in a digital format. The Trademark Office should
also revise its TEAS procedures to interface with industry
standard office automation programs before forcing people to
use TEAS. For example, this could be done by having online a
site where one can copy and paste an entire PRINTEAS
application, which the PTO computer would then process into
the TEAS format.

Finally, the mandatory e-filing leads to a punitive burden on
the public which should not be the focus of the United States
government efforts. The government's job is to facilitate the
function of society and its economy and should do its utmost
to ease its interaction to the public. By forcing everyone to
file on TEAS, this principle is violated as the government is
imposing undue burden on the small business, unsubstantiated
by any reasonable basis. The government should do its utmost
to facilitate the filing of trademarks by accepting scannable
filings on PRINTEAS, since those filings can be prepared by
anyone, without any need to maintain internet access,
computers, firewalls or credit card accounts; and can easily
be converted into electronic form.


In the Proposed Rules to Implement Madrid Protocol
Legislation, there is no provision to prevent unauthorized
practice of law by foreigners who are not members of the bar
of any state. Since no U.S. attorney or domestic
representative is needed to file an international application,
it is expected that a foreign applicant may answer an office
action without retaining a U.S. attorney, which will
eventually lead to unauthorized practice of law. Hence, the
Proposed Rule should have a provision that requires a response
to an office action to be filed by a U.S. admitted attorney.

Pursuant to the Guide to the International Registration of
Marks under the Madrid Agreement and the Madrid Protocol
published by the World intellectual Property Organization
implies that it is necessary for a foreign applicant to
appoint a domestic representative in case of an office action.
Sec. 11.04 states:

The appointment of a representative in the international
application only empowers him to act before the International
Bureau. It may subsequently become necessary to appoint one or
more further representatives to act before the Offices of
designated Contracting Parties, for example, in the event of a
refusal of protection issued by such an Office. The
appointment of a representative in such a case will be
governed by the requirements of the Contracting Party

Hence, the Proposed Rules overlook this section of the Guide
and they should be amended to include a provision which
requires appointment of a U.S. attorney in the event of an
office action. If non-qualified persons are permitted to reply
to office actions, the burden on the Office would be severe
since it is unlikely that foreign persons not admitted to
practice in the U.S., will have a proper understanding of our
laws and procedures. Moreover, to permit such acts would
unduly impact small business in the United States, since law
firms like ourselves would be deprived of business due to
unfair competition from foreign persons practicing U.S. law
without any license to do so.

For the above reasons, we earnestly request reconsideration
and revision of the Proposed Rules.


Respectfully submitted,

Robert M. Kunstadt
Managing Attorney

R. Kunstadt, P.C.
729 Seventh Avenue
New York, New York 10019
Ph: 212 398-8881
Fax: 212 398-2922





>>as always, reply only to<<


If the reader is not the intended recipient, or the employee
or agent responsible to deliver it to the intended recipient,
you are hereby notified that any dissemination, distribution
or copying of this communication is strictly prohibited. If
you have received this communication in error, please
immediately notify us. Thank you.


This is Exhibit A to the Comments of R. Kunstadt, P.C.:



Test Company
1234 Sample Drive


~[select only one]~


~enter YES, if a word mark~YES
~Attach a drawing sheet in all cases.~

~[select only those Sections that are appropriate and delete the others]~

~Applicant has a bona fide intention to use the mark in commerce, on or in connection with the below-identified goods and/or services (15 U.S.C. 1051 (b)).~


$0 ~for illustration only~

~Applicant requests registration of the above-identified mark in the United States Patent and Trademark Office on the Principal Register established by the Act of July 5, 1946 (15 U.S.C. 1051 et seq.) for the above-identified goods and/or services.

DECLARATION. The undersigned being hereby warned that willful false statements and the like so made are punishable by fine or imprisonment, or both, under 18 U.S.C. 1001 and that such willful false statements and the like may jeopardize the validity of the application or any resulting registration, declares that he/she is properly authorized to execute this application on behalf of the applicant; he/she believes the applicant to be the owner of the mark sought to be registered, or, if the application is being filed under 15 U.S.C. 1051(b), he/she believes the applicant to be entitled to use such mark in commerce; to the best of his/her knowledge and belief no other person, firm, corporation, or association has the right to use the mark in commerce, either in the identical form thereof or in such near resemblance thereto as to be likely, when used on or in connection with the goods and/or services of such other person, to cause confusion, or to cause mistake, or to deceive; and that all statements made of his/her own knowledge are true and all statements made on information and belief are believed to be true.

POWER OF ATTORNEY. The undersigned hereby appoints Robert M. Kunstadt, of the bar of the State of New York, of the firm R. Kunstadt, P.C., located at 729 Seventh Avenue, New York, New York 10019, its attorney to prosecute this application for registration, to transact all business in the Patent and Trademark Office in connection therewith, and to receive the certificate of registration. All correspondence is to be addressed to the firm.



Howie Tester
Test Pilot</p> <p><CONTACT INFORMATION></p> <p><Name> Robert M. Kunstadt, Esq.<br> <Company/Firm Name> R. 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