[Patentpractice] Extended Due Date/Sanity Check Question

Timothy Snowden tdsnowden at outlook.com
Wed Mar 12 17:55:38 UTC 2025


Well, better safe than sorry I guess.


On 3/12/2025 12:39 PM, David Boundy via Patentpractice wrote:
> Justice Gorsuch (while still on the Tenth Circuit) explained that one 
> relies on PTO subregulatory guidance to override a statute at one's 
> peril.  I couldn't remember the case until I hit send, then it came to 
> me https://scholar.google.com/scholar_case?case=3098648296141854653   
> The PTO doesn't have authority to waive the six month deadline just by 
> giving it an oddball name. "Any action" means "any action."  Whatever 
> authority the PTO had to torture statutes ended with Loper Bright last 
> summer.   The PTO structures its practices to maximize fee income, not 
> to give value to applicants.  When it comes to a choice between fee 
> revenue and the law, the law can go to hell.  So don't trust these 
> representations -- your opposing defendant won't.
>
>
>     On Wed, Mar 12, 2025 at 1:19 PM Sharon Rubin via Patentpractice
>     <patentpractice at oppedahl-lists.com> wrote:
>
>         As Timothy said, Missing Parts has always been interpreted as
>         2 month + 5 months.  2 different docketing systems we’ve used
>         agree, so it must be true!
>
>         Our current docketing system says with regard to Missing
>         Parts: “There are five extensions available, so the final time
>         can be 7 months after the date mailed.  See MPEP 710.02(d)
>         which explains why this time can go beyond 6 months.”
>
>         *MPEP**710.02(d)    Difference Between Shortened Statutory
>         Periods for Reply and Specified Time Limits [R-07.2015]*
>
>         **
>
>         “The 2-month time period for reply to A Notice to File Missing
>         Parts of an Application is not identified on the Notice as a
>         statutory period subject to 35 U.S.C. 133
>         <https://www.bitlaw.com/source/35usc/133.html>. Thus,
>         extensions of time of up to 5 months under 37 CFR 1.136(a)
>         <https://www.bitlaw.com/source/37cfr/1-136.html>, followed by
>         additional time under 37 CFR 1.136(b)
>         <https://www.bitlaw.com/source/37cfr/1-136.html>, when
>         appropriate, are permitted.”
>
>         *Sharon Rubin*
>
>         *From:*Patentpractice
>         <patentpractice-bounces at oppedahl-lists.com> *On Behalf Of
>         *Goldberg, Judi via Patentpractice
>         *Sent:* Wednesday, March 12, 2025 12:52 PM
>         *To:* For patent practitioners. This is not for laypersons to
>         seek legal advice. <patentpractice at oppedahl-lists.com>
>         *Cc:* Goldberg, Judi <jgoldberg at leydig.com>
>         *Subject:* Re: [Patentpractice] Extended Due Date/Sanity Check
>         Question
>
>         If the notice is dated 10/17/24, even with a two month
>         response date (i.e., 12/17/24), and assuming the normal 3
>         month extension available, the application wouldn’t be
>         abandoned until 3/*17*/25.
>
>         My understanding has always been that you get 4 months of
>         extension for a two month response date, and 5 months
>         extension on a one-month response, so everything equals a
>         total available time of 6 months.
>
>         Let us know what you find out from PTO Legal. Thanks!
>
>         Judi
>
>         *From:*Patentpractice
>         <patentpractice-bounces at oppedahl-lists.com> *On Behalf Of
>         *Suzannah K. Sundby via Patentpractice
>         *Sent:* Wednesday, March 12, 2025 11:44 AM
>         *To:* For patent practitioners. This is not for laypersons to
>         seek legal advice. <patentpractice at oppedahl-lists.com>
>         *Cc:* Suzannah K. Sundby <suzannah at canadylortz.com>
>         *Subject:* Re: [Patentpractice] Extended Due Date/Sanity Check
>         Question
>
>         *[External Email]*
>
>         Yeah, read what Boundy wrote and felt like everything I know
>         and understand was turned upside down…
>
>         Btw, PatentCrapper indicates that the Notice mailed on October
>         17^th is a Pre-Exam Formalities Notice.
>
>         I’m going to contact Patent Legal because the given case is a
>         mess.
>
>         12/22/2021 Received Notice of Acceptance
>
>         09/03/2024 Notice withdrawing the Notice of Acceptance
>
>         09/13/2024 Notice of DO/EO Missing Requirements Mailed
>
>         10/17/2024 Notice withdrawing the Notice mailed 09/13/2024;
>         Requirement for Sequence Listing setting 2 mo due date
>
>         03/12/2025 Abandonment Notice indicating no timely reply to
>         the Notice of 10/17/2024
>
>         Suzannah K. Sundby <http://www.linkedin.com/in/ssundby/>*|*
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>         *From:*Patentpractice
>         <patentpractice-bounces at oppedahl-lists.com> *On Behalf Of
>         *Timothy Snowden via Patentpractice
>         *Sent:* Wednesday, March 12, 2025 12:27 PM
>         *To:* patentpractice at oppedahl-lists.com
>         *Cc:* Timothy Snowden <tdsnowden at outlook.com>
>         *Subject:* Re: [Patentpractice] Extended Due Date/Sanity Check
>         Question
>
>         I see your point, but I know the office (FWIW) interprets
>         Missing Parts as having 5 month extension available, which is
>         what I was taught. I understood the keyword here in 35 USC 132
>         to be "ON EXAMINATION." But this isn't examination because
>         it's always /pre-/examination. In other words, although this
>         may be an action, it's during a pre-examination review, not
>         "on examination". Not sure how clearly that distinction
>         carries into other thing, though.
>
>         Have I been missing something for years now? What happens when
>         the office grants a patent after response to NTFMP at 7 months
>
>         On 3/12/2025 11:18 AM, David Boundy via Patentpractice wrote:
>
>             I think you have one more month, to total six months,
>             April 17.  I disagree with Tim Snowden -- the six month
>             deadline is statutory.   The statutory deadline applies to
>             all "objections or requirements" or "actions" even if the
>             underlying basis is regulatory.   "Action" is defined in 5
>             U.S.C. 551.   Look at sections 132 and 133 --
>
>
>               35 U.S.C. § 132 - Notice of rejection; reexamination
>
>             (a) Whenever, on examination, any claim for a patent is
>             rejected, or any objection or requirement made, the
>             Director shall notify the applicant thereof, stating the
>             reasons for such rejection, or objection or requirement,
>             together with such information and references as may be
>             useful in judging of the propriety of continuing the
>             prosecution of his application; and if after receiving
>             such notice, the applicant persists in his claim for a
>             patent, with or without amendment, the application shall
>             be re­examined. No amendment shall introduce new matter
>             into the disclosure of the invention.
>
>
>               35 U.S.C. § 133 - Time for prosecuting application
>
>             Upon failure of the applicant to prosecute the application
>             within six months after any action therein, of which
>             notice has been given or mailed to the applicant, or
>             within such shorter time, not less than thirty days, as
>             fixed by the Director in such action, the application
>             shall be regarded as abandoned by the parties thereto.
>
>             Five months extension is only available for a few
>             situations --
>
>                  -- teh initial time is one month
>
>                  -- teh deadline runs from some action of the
>             applicant (such as filing a Notice of Appeal) rather than
>             responding to an objection, requirement, or "any action"
>             of the PTO.
>
>             On Wed, Mar 12, 2025 at 11:15 AM Suzannah K. Sundby via
>             Patentpractice <patentpractice at oppedahl-lists.com> wrote:
>
>                 Received a Notification to Comply (with Sequence
>                 Listing Requirements), which is essentially a Notice
>                 of Missing Parts.
>
>                 The Notice was mailed October 17, 2024, and sets an
>                 extendible 2 month shortened due date.
>
>                 The USPTO just mailed a Notice of Abandonment for
>                 failing to timely respond.
>
>                 Thus, I need a sanity check:
>
>                 Because it is a 2-month shortened date, the due date
>                 can be extended by 5 months to May 17, 2025 – Correct?
>
>                 Suzannah K. Sundby
>                 <http://www.linkedin.com/in/ssundby/>*|* Partner
>
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