Jason Feldmar

To whom it may concern, Although transmitted subsequent to the requested deadline, please consider the following comment.

The proposed rules would implement an exception for ensuring a filing date when a response to an office action is not filed electronically. Please note that there is currently no capability to electronically file a response to a post registration Office Action (e.g., that rejects a section 8 & 15 declaration). Accordingly, the only method that can be used to ensure delivery and the establishment of a filing date is via express mail.

Such a requirement would potentially detrimentally affect Registrants. Accordingly, I would like to suggest that either (1) a post registration office action response be added to the electonic filing stystem, or (2) the issued rules clarify that the express mail procedure remains applicable for post registration office actions.

Thank you for your consideration,
- Jason Feldmar


Jason S. Feldmar
Gates & Cooper LLP
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