Subject: Comments on Proposed Changes

The proposed change to 2.174 and 175 are unfair with regard to the proposed time limit. As a transactional IP attorney, many mistakes in registrations are not discovered until years after the issuance of a registration especially those relating to title and company names. For example, use of LLC when Inc was appropriate. To prohibit the correction of the same will hamper commerce since it will unduly delay transactions (mergers, acquisitions, etc.) when title questions arise. This rule would also prohibit the acceptance of maintenance filings by the correct entity. Please reconsider.

Karl M. Zielaznicki, Esq.
Jenkens & Gilchrist Parker Chapin LLP
The Chrysler Building
405 Lexington Avenue
New York, NY 10174
Phone: 212-704-6125
Fax: 212-704-6288