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August 08, 2011



I realize that if the AIA is passed, there's going to be extensive rule making required. But I view Kappos call now for comments on such rule making to be premature. Until we know the final contours of the AIA, we're likely to waste much effort on provisions which may change, or which might not even remain in the AIA.


I look at this as another opportunity to press the Patent Office to one of its duties - helping create policy.

To that end, I have already provided a rather lengthy first glance point by point critique of the sectional summary.

That critique has been publicly posted at:


Thanks, I saw what you posted on Patently-O and have printed it out.

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