FOUNDED 1957
				GLS
			GOVERNMENT LIAISON SERVICES, INC.
			200 North Glebe Rd., Suite 321  Arlington, Virginia 22203
	(703) 524-8200		(800) 642-6564			Fax: (703)	525-8451

			August 21, 2006	

Commissioner for Trademarks
P.O. Box 1451
Alexandria, VA 22313-1451

Att: Mary Hannon

RE: FR Doc. Vol. 71, No. 121 page 36065 Request for Comments on Removal of  Paper Search Collection of Marks That Include Design Elements

Dear Ms. Hannon:

The United States Patent and Trademark Office is again proposing to remove paper search collections of trademark registrations from its public search facilities and replace them with electronic information collections. Upon review, we believe the removal of those records will have an adverse impact and that the plan is premature.

We have previously provided public comment attended public hearings on the proposed removal of the paper search records. To date, our concerns with regard to data entry and the ability to accurately search and/or retrieve thousands of trademark records have not been adequately addressed

Upon information and belief, we can assert that X-Search and TESS still suffer a considerable error rate in the historic data and an 11% error rate among recently issued registrations.

Further, we note that the planned USPTO implementation of an additional layer of design coding is imprudent in that it will not be applied to the historic data, resulting in thousands of trademark registrations that can be located through a proper search.

Similarly, although the USPTO maintains that Paris Convention marks, tribal insignia and other non registration data can be retrieved in X-Search and TESS, experience with the systems proves otherwise as much of the statutorily mandate information is not present in the search systems.

Thus, it seems premature, if not arbitrary and capricious to eliminate the paper search file until such time as significant improvement in the electronic systems data integrity can be verified.

Very truly yours,

Robert G. Forbes
08-21-2006
U.S. Patent & TMOfc/TM  Mail Rcpt Dt#22