Comment Letter to PTO, Control Numbers 0651-0031 and -0032 60-Day Notice, Initial Patent Applications and Patent Processing (Nov. 30, 2020)
180 Pages Posted: 14 Apr 2021 Last revised: 21 Mar 2022
Date Written: November 30, 2020
Abstract
Several collections of information should be removed from these two information collection requests before they are submitted to OMB for review. For one collection of information, the PTO estimates its cost savings at about $150,000 per year, while the public estimates burdens at nearly $200 million per year. This collection of information cannot be justified. Further, the PTO acted unlawfully in promulgating the rules calling for several collections of information, and this triennial review is a good time to prune them.
Keywords: patent law, administrative law, Administrative Procedure Act, Paperwork Reduction Act, Information Collection regulation, OMB (Office of Management and Budget), OIRA (Office of Information and Regulatory Affairs), Patent and Trademark Office (USPTO)
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