[Patentpractice] group letter (was venting - failure to download priority document from DAS)

Carl Oppedahl carl at oppedahl.com
Tue Aug 6 16:30:51 UTC 2024


Recall that we already sent a group letter about DAS.  You can read 
about it here: 
https://blog.oppedahl.com/letter-has-been-sent-to-the-commissioner-for-patents-about-das/ 
.  This was on February 22, 2020.

Oh and the new group letter can remind the reader that this is already 
our second time asking for the end of the foot-dragging. We asked for 
that in the group letter just mentioned, more than four years ago.

Oh and yes there is a tenth "ask" namely that RO/US become a Depositing 
Office in DAS.  We asked for this in the group letter of four years ago.

On 8/6/2024 10:20 AM, Carl Oppedahl wrote:
>
> Yeah, a group letter would be a good idea.  there would be multiple 
> "asks".
>
> First, can they stop the foot-dragging on the retrieval.  In present 
> procedure, they always foot-drag the retrieval until the case is 
> getting released from the OPAP to the Examining Corps. The correct 
> behavior would be to retrieve the ECC (electronic certified copy) 
> without delay, later the same day after the filer requests the retrieval.
>
> Second, can they eliminate the human hand-keyed aspect of this.  The 
> ADS provides the DAS access code in computer-readable characters.  The 
> USPTO should extract the computer-readable DAS access code from inside 
> the XML of the ADS, and should auto-load these computer-readable 
> characters directly into the retrieval system.  It is stupid to 
> flatten the ADS to an image, and then halftone it, and then resample 
> the DPI, and then ask a human being at the USPTO to read it and 
> hand-key it into the retrieval system.
>
> Third, can the USPTO please just take WIPO's example and provide a 
> USPTO click path (perhaps within Patent Center) by which the filer can 
> carry out the "action" (as in ePCT) of requesting the retrieval.  And 
> then the click path will do a real-time lookup in DAS and in real 
> time, the click path will display the results of the real-time 
> lookup.  In this way, the filer can instantly learn whether there is a 
> problem with the DAS code.  And then the actual retrieval should 
> proceed in an automatic way.
>
> Fourth, in the case where the filer is providing the DAS access code 
> in an ADS, can Patent Center simply extract the computer-readable DAS 
> access code from the ADS and validate it in real time against DAS, at 
> the time of the upload of the ADS.
>
> Fifth, in the case where the filer is providing the DAS access code in 
> a web-based ADS, can Patent Center simply validate it in real time 
> against DAS, at the time of the upload of the filer's entry of the DAS 
> access code into the web-based ADS.  Note that we first asked for this 
> in July of 2020.
>
> Sixth, Patent Center should display, in the foreign priority tab, the 
> results of the cross-check against DAS (success or failure).
>
> Seventh, Patent Center should display, in the foreign priority tab, 
> the results of the retrieval attempt from DAS.  If the retrieval from 
> DAS worked, Patent Center needs to say so, along with the date that it 
> happened and whether or not that date satisfies the 4-and-16 date.  If 
> the retrieval from DAS failed, Patent Center needs to say so.
>
> Eighth, any time that the USPTO tries to retrieve an ECC from DAS and 
> fails, the USPTO should explicitly communicate this failure to the 
> filer by means of an email notification, providing verbatim the text 
> of the error message from DAS.
>
> Ninth, any time that the USPTO tries to retrieve an ECC from DAS and 
> succeeds, the USPTO should explicitly communicate this success to the 
> filer by means of an email notification.
>
>
>
> On 8/6/2024 10:01 AM, Krista Jacobsen via Patentpractice wrote:
>> Thanks for the responses. There are a number of frustrating aspects 
>> to this.
>>
>> I will proceed with a "corrected" ADS, request for corrected filing 
>> receipt, and old SB/38 form. And, of course, an interim copy.
>>
>> Maybe this situation calls for another group letter? I can volunteer 
>> to draft one and circulate for comments (though probably not 
>> immediately).
>>
>> Best regards,
>> Krista
>>
>> ------------------------------------------
>> Krista S. Jacobsen
>> Attorney and Counselor at Law
>> Jacobsen IP Law
>> krista at jacobseniplaw.com
>> T:  408.455.5539
>> www.jacobseniplaw.com <http://www.jacobseniplaw.com>
>>
>>
>> On Tue, Aug 6, 2024 at 8:42 AM Carl Oppedahl via Patentpractice 
>> <patentpractice at oppedahl-lists.com> wrote:
>>
>>     What he said.  It is super important to set up tracking in the
>>     DAS system for every would-be priority document.
>>
>>     On 8/6/2024 9:09 AM, Randall Svihla via Patentpractice wrote:
>>>
>>>     Hi, Alan
>>>
>>>     Sometime the USPTO misreads the access code (B for 8 or 8 for B,
>>>     etc.) and submits the wrong access code,Sometimes the client
>>>     gives you the wrong access code.By setting up tracking in the
>>>     WIPO Digital Access Service, you can see these errors.
>>>
>>>     Best regards.
>>>
>>>     Randall S. Svihla
>>>
>>>     *From:*Patentpractice
>>>     <patentpractice-bounces at oppedahl-lists.com>
>>>     <mailto:patentpractice-bounces at oppedahl-lists.com> *On Behalf Of
>>>     *Alan Taboada via Patentpractice
>>>     *Sent:* Tuesday, August 6, 2024 11:04 AM
>>>     *To:* For patent practitioners. This is not for laypersons to
>>>     seek legal advice. <patentpractice at oppedahl-lists.com>
>>>     <mailto:patentpractice at oppedahl-lists.com>
>>>     *Cc:* Alan Taboada <ataboada at mtiplaw.com>
>>>     <mailto:ataboada at mtiplaw.com>
>>>     *Subject:* Re: [Patentpractice] venting - failure to download
>>>     priority document from DAS
>>>
>>>     In the past, we have submitted a corrected ADS with the DAS code
>>>     provided.
>>>
>>>     However, I would love to know if there is a better way to get
>>>     this done as, in our experience, the USPTO has been failing to
>>>     retrieve priority applications much more frequently and with
>>>     greater and greater hoops to be jumped through to try to get the
>>>     USPTO to electronically retrieve the certified copy of the
>>>     priority document.  In some cases, we needed to resort to
>>>     obtaining a paper version of the certified copy ourselves to
>>>     provide to the USPTO because the USPTO is incapable of obtaining it.
>>>
>>>     Having seen Randall’s email prior to hitting send, we will try
>>>     that to see if that gives us better results (thanks, Randall)!
>>>
>>>     *From:*Patentpractice
>>>     <patentpractice-bounces at oppedahl-lists.com>
>>>     <mailto:patentpractice-bounces at oppedahl-lists.com> *On Behalf Of
>>>     *Krista Jacobsen via Patentpractice
>>>     *Sent:* Tuesday, August 6, 2024 10:44 AM
>>>     *To:* For patent practitioners. This is not for laypersons to
>>>     seek legal advice. <patentpractice at oppedahl-lists.com>
>>>     <mailto:patentpractice at oppedahl-lists.com>
>>>     *Cc:* Krista Jacobsen <krista at jacobseniplaw.com>
>>>     <mailto:krista at jacobseniplaw.com>
>>>     *Subject:* Re: [Patentpractice] venting - failure to download
>>>     priority document from DAS
>>>
>>>     Hi all,
>>>
>>>     I have the same question as Erin, and I cannot find an answer.
>>>     Am I being dumb?
>>>
>>>     An application ("FPA") was filed in a non-U.S. office, but one
>>>     that participates in DAS.
>>>
>>>     A U.S. non-provisional application ("USNP") was filed and claims
>>>     priority to FPA.
>>>
>>>     The DAS code for FPA was not provided by the foreign associates
>>>     before USNP was filed, so the DAS code does not appear in the
>>>     field of the ADS.
>>>
>>>     The 4/16 deadline is approaching, and I need to request that the
>>>     USPTO retrieve a certified copy of FPA from DAS. (Will also be
>>>     submitting an interim copy in case they dawdle.)
>>>
>>>     It seems like it should be simple to do this ("Hi, here's the
>>>     DAS code for the application you already know about, please
>>>     retrieve it"), and yet I cannot figure out how.
>>>
>>>     Years ago when I had to do this, I submitted an SB/38 form,
>>>     which had an Option B that allowed the DAS code to be provided.
>>>     But that form is dated 2017 and seems to have been abrogated.
>>>
>>>     The current SB/38 form only "requests that the USPTO retrieve a
>>>     copy of the following foreign priority application(s) _that was
>>>     not filed in a foreign intellectual property office
>>>     participating with the USPTO in a priority document exchange
>>>     agreement_ ('Participating Office') but was submitted in an
>>>     application subsequently filed with a Participating Office that
>>>     permits the USPTO to retrieve such copy."
>>>
>>>     That is not my situation. I just need to provide a DAS code so
>>>     the USPTO can retrieve the application from another
>>>     Participating Office.
>>>
>>>     Do I submit a "corrected" ADS to provide the DAS code in the
>>>     foreign priority info section?
>>>
>>>     Is there a different form to do this that I have missed? I
>>>     looked through the list of forms provided by the USPTO and did
>>>     not see anything that seemed applicable.
>>>
>>>     Thanks in advance.
>>>
>>>     Best regards,
>>>
>>>     Krista
>>>
>>>     ------------------------------------------
>>>
>>>     Krista S. Jacobsen
>>>
>>>     Attorney and Counselor at Law
>>>
>>>     Jacobsen IP Law
>>>
>>>     krista at jacobseniplaw.com
>>>
>>>     T:  408.455.5539
>>>
>>>     https://link.edgepilot.com/s/ecbebddd/1VqL_JWTpkKQnA9grqI70g?u=http://www.jacobseniplaw.com/
>>>
>>>     On Thu, May 16, 2024 at 9:52 AM Erin Geraghty via Patentpractice
>>>     <patentpractice at oppedahl-lists.com> wrote:
>>>
>>>         That form seems to only allow for obtaining from an EP/JP
>>>         case in which the priority application was filed, right? 
>>>          It does not mention obtaining the document from WIPO.
>>>
>>>         /Please retrieve the foreign priority application identified
>>>         in Column C, a copy of which is contained in the EP or JP
>>>         application identified in Columns A and B:/
>>>
>>>         There does not appear to be an actual form for requesting
>>>         the PTO pull the priority document via DAS?  Am I missing
>>>         something?
>>>
>>>         Apologies if this is a stupid question, maybe I need more
>>>         caffeine.
>>>
>>>         Regards,
>>>
>>>         Erin D. Geraghty
>>>
>>>         Office Manager
>>>
>>>         Browdy and Neimark, PLLC
>>>
>>>         1625 K Street, N.W., Suite*550*
>>>
>>>         Washington, D.C.  20006
>>>
>>>         Tel: 443-386-7495
>>>
>>>         Fax: 202-737-3528
>>>
>>>         ering at browdyneimark.com <mailto:ering at browdyneimark.com>
>>>
>>>         https://link.edgepilot.com/s/6fc120a4/mTMmW11UIk6za0lZSfZcWg?u=http://www.browdyneimark.com/
>>>         <https://link.edgepilot.com/s/6fc120a4/mTMmW11UIk6za0lZSfZcWg?u=http://www.browdyneimark.com/>
>>>
>>>
>>>         PLEASE NOTE OUR NEW SUITE NUMBER!
>>>
>>>         /This message and any attached files is intended for the
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>>>
>>>         *From:*Patentpractice
>>>         <patentpractice-bounces at oppedahl-lists.com> *On Behalf Of
>>>         *Randall Svihla via Patentpractice
>>>         *Sent:* Thursday, May 16, 2024 11:50 AM
>>>         *To:* For patent practitioners. This is not for laypersons
>>>         to seek legal advice. <patentpractice at oppedahl-lists.com>
>>>         *Cc:* Randall Svihla <rsvihla at nsiplaw.com>
>>>         *Subject:* Re: [Patentpractice] venting - failure to
>>>         download priority document from DAS
>>>
>>>         Have you ever try just filing a PTO/SB/38 Request to
>>>         Retrieve Electronic Priority Application(s) (the old form
>>>         with options A and B) to see if they would retrieve it?
>>>
>>>         *From:*Patentpractice
>>>         <patentpractice-bounces at oppedahl-lists.com> *On Behalf Of
>>>         *Linda Zaveta via Patentpractice
>>>         *Sent:* Thursday, May 16, 2024 10:24 AM
>>>         *To:* For patent practitioners. This is not for laypersons
>>>         to seek legal advice. <patentpractice at oppedahl-lists.com>;
>>>         Dan Feigelson <djf at iliplaw.com>
>>>         *Cc:* Linda Zaveta <lzaveta at mtiplaw.com>
>>>         *Subject:* Re: [Patentpractice] venting - failure to
>>>         download priority document from DAS
>>>
>>>         It’s even more frustrating when they check the box on the OA
>>>         or NOA saying it was received and it hasn’t been.  This
>>>         happens a lot and when we check Patent Center, it isn’t
>>>         there.  Then we have to try and get in touch with someone to
>>>         request that they retrieve it.
>>>
>>>         *Sincerely**,*
>>>
>>>         *Linda*
>>>
>>>         Linda Zaveta |Paralegal
>>>
>>>         *MOSER TABOADA*
>>>
>>>         1040 Broad Street, Suite 103
>>>
>>>         Shrewsbury, NJ  07702
>>>
>>>         lzaveta at mtiplaw.com
>>>
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>>>         *From:*Patentpractice
>>>         <patentpractice-bounces at oppedahl-lists.com> *On Behalf Of
>>>         *Erin Geraghty via Patentpractice
>>>         *Sent:* Thursday, May 16, 2024 10:05 AM
>>>         *To:* Dan Feigelson <djf at iliplaw.com>; For patent
>>>         practitioners. This is not for laypersons to seek legal
>>>         advice. <patentpractice at oppedahl-lists.com>
>>>         *Cc:* Erin Geraghty <ErinG at browdyneimark.com>
>>>         *Subject:* Re: [Patentpractice] venting - failure to
>>>         download priority document from DAS
>>>
>>>         I agree this is incredibly frustrating!  Especially as they
>>>         do not notify you when they have successfully obtained it
>>>         via DAS except by checking a box on an OA or NOA.  It is
>>>         even more troubling when for some reason they run into an
>>>         issue and do not let you know they have encountered an issue.
>>>
>>>         Also, when they have not properly downloaded it, the
>>>         responsible parties at the PTO are less than helpful when
>>>         trying to figure out what happened.
>>>
>>>         Regards,
>>>
>>>         Erin D. Geraghty
>>>
>>>         Office Manager
>>>
>>>         Browdy and Neimark, PLLC
>>>
>>>         1625 K Street, N.W., Suite*550*
>>>
>>>         Washington, D.C.  20006
>>>
>>>         Tel: 443-386-7495
>>>
>>>         Fax: 202-737-3528
>>>
>>>         ering at browdyneimark.com <mailto:ering at browdyneimark.com>
>>>
>>>         https://link.edgepilot.com/s/9dfe1008/kXVrrzwvxEy9arq3DTQX1A?u=http://www.browdyneimark.com/
>>>         <https://link.edgepilot.com/s/9dfe1008/kXVrrzwvxEy9arq3DTQX1A?u=http://www.browdyneimark.com/>
>>>
>>>
>>>         PLEASE NOTE OUR NEW SUITE NUMBER!
>>>
>>>         /This message and any attached files is intended for the
>>>         above-named recipient(s). This message may be an
>>>         attorney-client communication containing confidential and
>>>         priviliged information. If the reader of this message is not
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>>>
>>>         *From:*Patentpractice
>>>         <patentpractice-bounces at oppedahl-lists.com> *On Behalf Of
>>>         *Dan Feigelson via Patentpractice
>>>         *Sent:* Thursday, May 16, 2024 8:22 AM
>>>         *To:* For patent practitioners. This is not for laypersons
>>>         to seek legal advice. <patentpractice at oppedahl-lists.com>
>>>         *Cc:* Dan Feigelson <djf at iliplaw.com>
>>>         *Subject:* [Patentpractice] venting - failure to download
>>>         priority document from DAS
>>>
>>>         Image removed by sender.
>>>
>>>         Filed an application that claims priority only from a non-US
>>>         application. Foreign priority app is in DAS (I checked with
>>>         WIPO). Provided the USPTO with the foreign application no.
>>>         and the DAS retrieval code on an ADS at the time of filing.
>>>         Got the filing receipt, and it acknowledges the foreign
>>>         priority claim and that the DAS code was provided, and says
>>>         that the USPTO "will attempt to electronically retrieve" the
>>>         priority doc. But of course, the p.d. isn't yet in the
>>>         electronic file.
>>>
>>>         That the PTO waits to retrieve the p.d. is not news, Carl
>>>         and others have written about it. But it still bugs me: how
>>>         hard would it be for the PTO to retrieve the document NOW
>>>         instead of waiting?
>>>
>>>         Dan
>>>
>>>
>>>
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