Comments on Question 7

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QUESTION 07:
     Should the PTO require an affirmative communication from a patent
     applicant indicating that the applicant does not wish the
     application to be published, or should failure to timely submit a
     publication fee be taken as instruction not to publish the 
     application? That is, should an application be published unless
     the applicant affirmatively indicates that the application is not
     to be published, regardless of whether a publication fee has been
     submitted? What latitude should the PTO permit for late submission
     of a publication fee?

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FROM RESPONDENT 001:
     
     NAME:               David E. Craword, Jr. (Reg No. 38,118)
     COMPANY:            ROGERS, HOWELL & HAFERKAMP
                         COUNSELLORS AT LAW
     ADDR-1:             PIERRE LACLEDE CENTER, SUITE 1400
                         7733 F0RSYTH BOULEVARD
     CITY, STATE ZIP:    ST.LOUIS, MISS0URI 63105-1817
     TELEPHONE:          (314) 727-5188
     FAX:
     REPRESENT:          unclear
     

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COMMENT ON QUESTION 07:
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     001-Q07.TXT
     The PTO should require an affirmative communication indicating that
     the application is to be published along with submission of a
     publication fee. If the fee is unpaid, the application should be
     automatically abandoned subject to revival due to unavoidable or
     unintentional delay in filling the fee.

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FROM RESPONDENT 026:
     NAME: Louis Maassel 
     COMPANY: World Intellectual Property Organization, Geneva, Switzerland 
     ADDR-1: 12716 Buckingham Drive 
     CITY, STATE ZIP: Bowie, Maryland 20715
     TELEPHONE: 301) 464-4306
     FAX: 
     REPRESENT: self
     

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COMMENT ON QUESTION 07:
     Under the PCT, all international applications are published promptly after the expiration of 18 months from the priority date except those which fall under the reservation of Article 64(3) and those      which have been withdrawn prior to the date on which "technical preparations for international publication have been completed." (PCT Rule 90bis. l(c)). This date on which "technical preparations f     or international publication have been completed" is 15 days prior to the international publication date. Publication is currently every Thursday. Withdrawal of an international application may also      be made provisional so that if the notice of withdrawal arrives too late to stop publication that the applicant is not faced with a publication of a withdrawn application. A similar conditional aba     ndonment practice should be adopted by the USPTO.

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FROM RESPONDENT 041:
     NAME: Frederick S. Burkhart 
     COMPANY: INTELLECTUAL PROPERTY LAW SECTION
       OF THE. STATE. BAR OF MICHIGAN 
     ADDR-1: 306 TOWNSEND STREET 
     CITY, STATE ZIP: LANSING, MICHIGAN 48933
     TELEPHONE: 517-372-9030
     FAX: 
     REPRESENT: association
     

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COMMENT ON QUESTION 07:
     The Patent and Trademark Office should publish an application unless affirmative communication is received from a patent Applicant, indicating that the Applicant does not wish the application to be      published. 

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FROM RESPONDENT 019:
     NAME:	Wilmot H. McCutchen, President
     COMPANY:	HOUSTON INVENTORS ASSOCIATION 
     ADDR-1:	
     CITY, STATE ZIP:	HOUSTON, TEXAS
     TELEPHONE:	(713) 957 4344
     FAX:	(713) 868-4104
     REPRESENT:	COMPANY
     

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COMMENT ON QUESTION 07:
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     019-Q07.TXT
     	Because the publication under option is (Appendix "A" format) is
     innocuous, ~ publication cutoff date (i.e. a date where the applicant
     would have to elect between publication or abandonment of his patent
     application) would be immaterial, except as to applicants guilty of
     dilatory prosecution. 	The concern with submarine patents may b~
     addressed by compulsory full publication at some time later than a
     flat 18 months where it {s clear that dilatory prosecution is taking
     place, in the opinion of the examiner. We can see no good reason to
     publish under options it, iii, or iv, everyone's application- at 18
     months, whether they are guilty of dilatory prosecution or not.
     	Under our proposal, the only cave in which a publication
     sufficiently enabling to b~ harmful to the- applicant would be
     available would b~ where there is a finding of dilatory prosecution
     (potential submarine patent) by the examiner, whereupon the applicant
     should be given a choice whether to continue with prosecution (having
     had the application more fully published) or to abandon the
     application and avoid further publication of an enabling natures.
     	But why treat all inventors as if they were guilty of dilatory
     prosecution? That is what this rule seeks to do presumes bad faith on
     the part of all applicants and then punish them by publishing an
     enabling disclosure of their applications after 18 months, which is
     often before even the first office action.

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FROM RESPONDENT 010:
     NAME:	Scott Weide 
     COMPANY:	QUIRK & TRATOS 
     ADDR-1:	550 E. CHARLESTON BLVD. . SUITE D 
     CITY, STATE ZIP:	LAS VEGAS NEVADA 89104
     TELEPHONE:	(702) 386-1778
     FAX:	
     REPRESENT:	firm
     

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COMMENT ON QUESTION 07:
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     010-Q07.TXT
     NWith the publication fee built into the filing fee, no separate
     publication fee is necessary. The PTO would not then need to address
     the issue of whether an application should be published. If the
     application has not been expressly abandoned, it should be published.
     There is then no need for latitude in submitting late publication
     fees.
     
     Allowing late payment of the publication fee is undesirable because
     it would provide an incentive to file multiple applications and would
     provide an undue advantage to foreign applicants.  

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FROM RESPONDENT 029:
     NAME:	Marcia H. Sundeen
     COMPANY:	PENNIE & EDMONDS 
     ADDR-1:	1701 Pennsylvania Avenue, N.W.
     CITY, STATE ZIP:	Washington, D.C. 20006-4706
     TELEPHONE:	(202) 393-0177
     FAX:	(202) 393 0462
     REPRESENT:	PTO Relations Committee
     

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COMMENT ON QUESTION 07:
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     029-Q07.TXT
     The PTO should require an affirmative communication from a patent
     applicant when the applicant does not wish for the application to be
     published. This should be done in a manner similar to that of the PCT
     where a communication must be submitted at least two weeks in advance
     of the anticipated publication date when an application is to be
     withdrawn. 

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FROM RESPONDENT 033:
     NAME:	TOM EASTEP
     COMPANY:	THE ALLIANCE FOR AMERICAN INNOVATION 
     ADDR-1:	1100 Connecticut Ave. NW, Suite 1200
     CITY, STATE ZIP:	Washington, D.C 20036-4101
     TELEPHONE:	202-293-1414
     FAX:	202-467-5591
     REPRESENT:	ALLIANCE FOR AMERICAN INNOVATION
     

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COMMENT ON QUESTION 07:
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     033-Q07.TXT
     THE ANSWERS TO QUESTION 7 ARE YES, NO, AND SHOULD BE DEFINITE, IN
     THAT ORDER.

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FROM RESPONDENT 008:
     NAME: Gabriel P. Katona
     COMPANY: 	Schweitzer Cornman & Gross
     		Attorneys at Law
     ADDR-1:	230 Park Avenue
     CITY, STATE ZIP:	New York, New York 10169-0059
     TELEPHONE: (212) 986-3377
     FAX: (212) 986-6126
     REPRESENT: unclear
     

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COMMENT ON QUESTION 07:
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     008-Q07.TXT
     The applicant should have an opportunity to (and the burden of)
     affirmatively withdrawing the application from publication, via
     Express Mail, until up to 17 months after filing of the permanent
     application This is in keeping with the socially desirable purpose of
     making publication as early and as likely to occur by taking place as
     automatically as possible.

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FROM RESPONDENT 004:
     NAME:     Michael H. Minns
     COMPANY:  INGERSOLL-RAND COMPANY
               Patent Department
     ADDR-1:   942 Memorial Parkway
     CITY, STATE ZIP:    Phillipsburg, NJ 08865
     TELEPHONE:     (908)859-7700
     FAX: (908) 859-7707
     REPRESENT:     self
     

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COMMENT ON QUESTION 07:
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     004-Q07.TXT
     The publication fee should be included with the application fee. The
     application should be published, even if abandoned, unless the
     applicant files an express request of abandonment.


Last Modified: March 1995