[Patentcenter] Assignment Center letter submitted to OMB

[David Boundy]

Surprise surprise.   The comment period is still open today at
https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202408-0651-004    If
you have any anecdotes about Ass Center (either patent or trademark), drop
them in.

The relief to ask for is estimates for burden.  The Paperwork Reduction Act
operates on an honor system, or embarrassment.  If the numbers get too big,
then OMB leans on agencies a little harder, and can even deny a clearance
(that's what happened with continuations/claims/appeals in 2009, I think
it's what happened to the CLE rule in 2021, it's what we're trying to get
for DOCX in 2024).   But the first-line measuring tool is burden
estimates.  So the punch line of your comment should be "The PTO's
estimates should be increased by ...."  (They currently estimate 40 minutes
per recordation -- remember that a few outliers can pull an average up by a
lot.)

The second theme I tried to draw is "Assignment Center is terrible, and
it's only one symptom of a pattern of bad software -- Patent Center is bad,
Assignment Center is bad, DOCX is bad.  Bad software creates substantial
burden.  Ass Center isn't one set of bugs, it's symptom of pattern and
practice.  The problem is bad software engineering."  If you want to add
another verse to that song, go for it.

If the interface will let you include a Sundby Angry Fish, go for it.

Our letter is at https://papers.ssrn.com/abstract=4975995 if you want to
plagiarize.  If you want to see a lot of the letters we've sent over the
years, see http://ssrn.com/author=2936470
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Thanks

On Thu, Oct 3, 2024 at 4:59 PM David Boundy <DavidBoundyEsq at gmail.com>
wrote:

> Letter submitted.  Thank you.   The final is at
> https://ssrn.com/abstract=4975995
>
> Eventually, it will be visible at OMB's web site, reginfo.gov at
> https://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=202408-0651-004
> But not until the PTO flips a switch.  Over the last couple years, the PTO
> now delays flipping that visibility switch until OMB completes its review.
> That might be six months.
>
> --
>
>
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>
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-- 


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*David Boundy *| Partner | Potomac Law Group, PLLC

P.O. Box 590638, Newton, MA  02459

Tel (646) 472-9737 | Fax: (202) 318-7707

*dboundy at potomaclaw.com <dboundy at potomaclaw.com>* | *www.potomaclaw.com
<http://www.potomaclaw.com>*

Articles at http://ssrn.com/author=2936470 <http://ssrn.com/author=2936470>
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