[E-trademarks] Trademark Center supposedly did get beta-tested!?

[David Boundy]

>
> And no, I did not know that the PRA supposedly puts a cap on how many beta
> testers are permitted ("9").  It sort of looks like a made-up excuse for
> failing to do proper beta testing.  The PRA was in place back when I served
> as
>
Your email was forwarded to me for further information about Trademark
> Center testing. As you know, the Paperwork Reduction Act constrains the
> research options of federal agencies, so our customer experience team
> conducts standardized research using groups of volunteers numbering 9 or
> fewer. We also conduct direct observations and one-on-one user sessions.
>
> Yes, the Paperwork Reduction Act has a step function of work for agencies
at ten.  But for this kind of testing and survey and similar stuff, the PRA
has a "lightweight" filing path. (I will look it up if someone asks.)  Yes,
clearing a beta test will take the PTO's regulatory counsel a couple
hours.  But it's much less than all the tasks that this person has
represented as de minimis or previously cleared.  (DOCX, the CLE rule, the
Terminal Disclaimer rule, several of the rules implemented as fee-setting,
etc.).   I don't know exactly who this person is, but I have heard through
several channels that he/she gives this "oh dear we can't do THAT" to many
internal clients (that's why the PTO can't do surveys at live events, and
the like), simply to get out of work.
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