Subject: PTO Proposed Rules to Implement Madrid Protocol Legislation

Honorable Commissioner for Trademarks
2900 Crystal Drive
Arlington, VA 222202

Attention: Cheryl L. Black


I am writing in opposition to the proposed amendment to Section 2.146(i)
insofar as it proposes to shorten the time during which an applicant must
check the status of a pending matters from one year to six months in order
to be diligent.

There are several reasons why the proposed amendment is inappropriate. The
principal reason is that it imposes upon applicants an undue burden and
expense to check for Trademark Office errors, i.e., where the "papers were
lost or mishandled" by the Office. This is particularly true since the
Office is now at times taking in excess of six months to assign newly filed
applications to Examiners (and Examiners are taking in excess of six months
to act upon original or amended applications), and it is at times taking
the Office more than six months to act upon applications for renewal or
affidavits of use, and these delays can only be expected to increase when
Madrid becomes implemented.

I am unaware of significant problem caused by the present one-year period.

If there is a compelling need to shorten this time period of which I am
unaware, under present Trademark Office delays, nine months would be more
appropriate that six months.

Respectfully submitted,

Albert Robin
Robin, Blecker & Daley
330 Madison Avenue
New York, New York 10017
Tel: (212) 682-9640
Fax: (212) 682-9648