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AIPLA Comments to:


Copyright Office

  • AIPLA Comments to DMCA Rulemaking Regarding Exemptions to Prohibition on Circumvention of Copyright Protection Systems for Access Control Technologies, submitted February 2, 2009. (PDF)
  • AIPLA Comments on the Notice of Inquiry regarding the issues raised by “orphan works," submitted May 8, 2005 (PDF – 3 pages - 39K*)

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Internal Revenue Service

  • AIPLA Testimony on proposed revisions to 26 C.F.R. Parts 1 and 301, delivered February 21, 2008 before the Internal Revenue Service. (PDF)
  • AIPLA Response to the October 2007 rule proposed by the U.S. Internal Revenue Service (IRS) on “Patented Transactions,”submitted December 26, 2007 (3 pages - 37K* - Click HERE to view the Response; clickHERE to view the IRS proposed rule (10/2007)..

Federal Drug Administration

  • AIPLA Comments re FDA Implementation of the Q1 Act, submitted January 30, 2009. (PDF)

Federal Trade Commission

  • AIPLA Comments on Section 5 Workshop, filed October 24, 2008 (PDF)
  • AIPLA Response to the Decision and Proposed Consent Order in the N-Data proceeding, filed April 5, 2008 (PDF)
  • AIPLA Response to the October 2003 FTC Report, Submitted April 21, 2004 (51 pages - 350K* - Click HERE to view the Response; Click HERE to view the FTC Report, 10/2003)

Department of Justice

  • AIPLA Response to the Antitrust Modernization Commission Regarding Questions for Public Comment on Its New Economy Study Plan (PDF – 11 pages - 67K*)

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Patent and Trademark Office

  • AIPLA Comments on Incentivizing Humanitarian Technologies, submitted November 19, 2010. (PDF)
  • AIPLA Comments on the TTAB’s Accelerated Case Resolution "Plug and Play" Proposal, submitted September 29, 2010. (PDF)
  • AIPLA Comments on the Interim Guidance for Determining Subject Matter Eligibility for Process Claims in View of Bilski v. Kappos, submitted September 27, 2010 (PDF)
  • AIPLA Comments on the “Enhanced Examination Timing Control Initiative” (75 Fed. Reg. 31763 (June 4, 2010)), submitted August 20, 2010. (PDF)
  • AIPLA Comments on Proposed Changes to Restriction Practice in Patent Applications Requesting, August 13, 2010. (PDF)
  • AIPLA Comments to the Patent and Trademark Office Draft Strategic Plan for FY 2010–2015, August 2, 2010. (PDF)
  • AIPLA Comments to Honorable Gary Locke re resources available to the U.S. Patent and Trademark Office, July 14, 2010. (PDF)
  • AIPLA Letter on Enhancement in the Quality of Patents and Metrics, June 23, 2010. (PDF)
  • AIPLA Comments to the Patent and Trademark Office Fee Modernization Act of 2010, May 17, 2010. (PDF)
  • AIPLA Comments on “Trademarks Next Generation” Information Technology Initiative, filed April 15, 2010 (PDF)
  • AIPLA Comments on Enhancement in the Quality of Patents; 74 Federal Register 65093 (December 9, 2009), filed April 5, 2010 (PDF)
  • AIPLA Comments on Pilot Program for Green Technologies Including Greenhouse Gas Reduction,” 74 Federal Register 64666 (December 8, 2009), filed April 2, 2010 (PDF).
  • AIPLA Comments on revisions to proposed rules on practice before the Board of Patent Appeals and Interferences in ex parte patent appeals, 74 Fed. Reg. 67987 (Dec. 22, 2010), filed February 25, 2010 (PDF);
  • AIPLA comments on discussion of proposed rules at January 20, 2010 Roundtable on the proposals, filed February 25, 2010 (PDF).
  • AIPLA Comments in response to the Notice of the U.S. Patent and Trademark Office (PTO) regarding Procedures for Treating Rejected Claims That Are Not Being Appealed, filed January 13, 2010. (PDF)
  • AIPLA Comments on Improvement of the USPTO’s efficiency, operation and utilization of the PCT, filed January 8, 2010. (PDF)
  • AIPLA Comments on USPTO’s Work Sharing for Patent Applications, filed December 11, 2009. (PDF)
  • AIPLA Encourages the Administration to move forward in implementing Resolution of Advice and Consent to the ratification of the Patent Law Treaty as well as to ratification of the Geneva Act of the Hague Agreement concerning the International Registration of Industrial Designs, filed July 22, 2009. (PDF)
  • AIPLA Comments on Deferred Examination for Patent Applications, filed February 26, 2009. (PDF)
  • AIPLA Comments on Proposed Changes to Practice for Documents Submitted to the United States Patent and Trademark Office, filed October 6, 2008 (PDF)
  • AIPLA Comments on Proposed Changes to the PCT Transmittal and Search Fees, filed August 15, 2008 (PDF)
  • AIPLA Comments on design patents as invited by the USPTO at the Town Hall Meeting on the Protection of Industrial Designs which it hosted on June 16 in Alexandria, Virginia, filed July 15, 2008 (PDF)
  • AIPLA Comments on encouraging enhancement of the quality of international searches and examinations and their greater use in national stage processing, filed May 23, 2008 (PDF)
  • AIPLA Comments on Proposed Rules Concerning the Changes in Rules Regarding Filing Trademark Correspondence by Express Mail, filed April 29, 2008 (PDF)
  • AIPLA Comments on Proposed Rules Concerning the Time for Filing and the Date of Availability of a Biological Deposit, filed April 21, 2008 (PDF)
  • AIPLA Comments on the proposed revision of the rules of practice pertaining to claims using alternative language, filed October 15, 2007 (PDF)
  • AIPLA Comments on the proposed changes to the rules governing practice before the Board of Patent Appeals and Interferences in ex parte patent appeals, 72 Federal Register 41472 (July 30, 2007), filed September 28, 2007 (PDF)
  • AIPLA Comments on “International Efforts to Harmonize Substantive Requirements of Patent Laws,” 72 Federal Register 24566 (May 3, 2007), filed June 22, 2007 (PDF)
  • AIPLA Comments on the Supplemental Notice of Proposed Rule Making on “Changes to Representation of Others Before the USPTO," filed May 26, 2007 (PDF)
  • AIPLA Comments on Proposed Rule Changes in the: “Requirements for Filing Requests for Reconsideration of Final Office Actions in Trademark Cases", filed April 16, 2007 (PDF)
  • AIPLA Comments on the Final Rule re Changes to Implement Priority Document Exchange Between Intellectual Property Offices, March 21, 2007 (PDF)
  • AIPLA Comments on the Proposed Rule Making entitled “April 2007 Revision of Patent Cooperation Treaty Procedures” filed March 16, 2007 (PDF)
  • AIPLA Comments on Proposed Rule: “Changes to Request for Reconsideration After Final Action” 72 Federal Register 6984, filed February 14, 2007 (PDF)
  • AIPLA Comments of AIPLA on the Government Working Group Report on the concept of a Global Patent Application, filed January 31, 2007 (PDF)
  • AIPLA Comments to the Patent Public Advisory Committee of the United States Patent and Trademark Office in response to a solicitation for input from stakeholders [REQUEST] on steps the USPTO can take to enhance the quality of examination, reduce pendency, and improve the efficient and effective use of patents, filed January 29, 2007 [RESPONSE]
  • AIPLA Comments on USPTO 2007-12 Strategic Plan, filed October 6, 2006 (PDF)
  • AIPLA Comments on Changes to Information Disclosure Statement Requirements, filed September 6, 2006 (PDF)
  • AIPLA Comments on the proposed rules on the “Removal of Paper Search Collection of Marks That Include Design Elements," filed August 22, 2006 (PDF)
  • AIPLA Comments on the Interim Guidelines for Examination of Patent Applications for Patent Subject Matter Eligibility, filed July 28, 2006 (PDF)
  • AIPLA Comments on the proposed rules: "Revisions and Technical Corrections Affecting Requirements for Ex Parte and Inter Partes Reexamination - 71 Fed. Reg. 16072 (March 30, 2006), filed May 30, 2006 (PDF)
  • AIPLA Comments on the proposed notice to eliminate the Disclosure Document Program —71 Fed. Reg. 17399 (April 6, 2006), filed May 3, 2006 with The Honorable Jon Dudas (PDF)
  • AIPLA Comments on Proposed Rules: Changes to Practice for Continuing Applications, Requests for Continued Examination Practice, and Applications Containing Patentably Indistinct Claims” 71 Fed. Reg. 48 (January 3, 2006), filed April 24, 2006 with The Honorable Jon Dudas (PDF)
  • AIPLA Comments on Proposed Rules: “Changes to Practice for the Examination of Claims in Patent Applications” 71 Fed. Reg. 61 (January 3, 2006), filed April 24, 2006 with The Honorable Jon Dudas (PDF)AIPLA
  • Comments on Proposed Changes to TTAB Rules, filed March 16, 2006, with The Honorable Jon Dudas (HTML, PDF)
  • AIPLA Comments on Electronic Filing of International Patent Applications, filed January 2, 2006, with The Honorable Jon Dudas (PDF)
  • AIPLA Comments on: Choice of International Searching Authorities, filed November 25, 2005 (HTML)
  • AIPLA Comments on the PTO's advance notice of proposed rule making regarding the acceptance, processing, use and dissemination of chemical and three-dimensional biological structural data in electronic format, August 22, 2005 (PDF)
  • AIPLA Comments on the proposed changes to implement the patent search fee refund provisions of the 2005 Consolidated Appropriations Act, August 22, 2005 (PDF)
  • Resolution: Harmonization of Patent Systems, May 2005 (PDF – 67K*)
  • AIPLA Comments to the Notice of Proposed Rule Making: “Requirements to Receive a Reduced Fee for Filing an Application through the “Trademark Electronic Application System” 70 Federal Register 17636 (April 7, 2005) (PDF - 30K*)
  • AIPLA Comments the Interim Rule on the Revision of Search and Examination Fees for Patent Cooperation Treaty Applications, submitted April 1, 2005 (PDF - 40K*)
  • AIPLA Comments on Proposed Rule: “Changes to the Practice for Handling Patent Applications Filed Without the Appropriate Fees," submitted March 29, 2005 (PDF - 23K*)
  • AIPLA Comments to the USPTO on the Interim Rule to Implement the Cooperative Research and Technology Enhancement Act of 2004, submitted February 10, 2005 ( PDF - 45K*)
  • Industry Trilateral comments on Proposed PCT Filing Fee Increase, September 22, 2004 (PDF – 287K*)
  • AIPLA Comments to Under Secretary of Commerce for Intellectual Property and Director of the United States Patent and Trademark Office regarding the PCT Fee increases, submitted September 13, 2004. (HTML or PDF)
  • AIPLA Comments on the revisions to the enrollment and discipline rules proposed December 12, 2003 (68 Fed. Reg. 69442), subject to the notices extending the comment period (69 Fed. Reg. 4269 (January 29, 2004) and 69 Fed. Reg. 9986 (March 3, 2004)). The comments and suggestions below address the proposed definitions of Subpart A, Subpart D, and the proposed rules in general as they relate to Subpart D. (Comments submitted on June 6, 2004) PDF only (208K)
  • Resolution for a Path Forward in WIPO Harmonization Talks from the Industry Trilateral, February 2004 (PDF – 229K*)
  • AIPLA Comments on the Equities of Inter Partes Reexamination Proceedings in Response to the Notice and Invitation Published at 68 Fed. Reg. 75217 (December 30, 2003) (Comments submitted on February 20, 2004). HTML or PDF (48K)
  • AIPLA Comments on the Notice of Proposed Rulemaking Changes to Representation of Others Before the Patent and Trademark Office 68 Federal Register 69442 (December 12, 2003) (Comments submitted on February 7, 2004). PDF (86K)
  • AIPLA Comments on the proposed changes to the rules governing practice before the Board of Patent Appeals and Interferences, 68 Federal Register 66648 (November 26, 2003) (Comments submitted on January 26, 2004). PDF (121K)
  • AIPLA Comments on Notice of Office Plan to Cease Supplying Copies of Cited U.S. Patent References With Office Actions, and Pilot to Evaluate the Alternative of Providing Electronic Access to Such U.S. Patent References (Comments submitted on January 15, 2004). HTML or PDF (48K)

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The Sedona Conference

  • AIPLA Comments on the Sedona Conference Report on the Markman Process, submitted February 2, 2007 (PDF)
  • AIPLA Comments on the Revised April 2005 Public Comment Draft" of The Sedona Guidelines: Best Practices Addressing Protective Orders, Confidentiality & Public Access in Civil Cases (the "Draft Guidelines"). Filed May 14, 2006. (PDF)
  • Letter expressing initial concerns of AIPLA on the Revised April 2005 Public Comment Draft" of The Sedona Guidelines: Best Practices Addressing Protective Orders, Confidentiality & Public Access in Civil Cases (the "Draft Guidelines"). Filed March 10, 2006. (PDF)

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United States Trade Representative


United States International Trade Commission

  • AIPLA Comments on proposed revisions to 19 C.F.R. Sections 201 and 210, filed March 19, 2008 at the US International Trade Commission (PDF)


The National Academies

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The National Institute of Health

  • Comments on Draft Report to the Secretary of Health and Human Services: "Public Consultation Draft Report on Gene Patents and Licensing Practices and Their Impact on Patient Access to Genetic Tests" 74(52) Federal Register 11730 (March 19, 2009) (PDF)

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ICANN

  • AIPLA comments regarding Version 4 of the Draft Application Guidebook ("DAG 4") for the introduction of new generic top-level domains ("gTLDs"), filed July 21, 2010 (PDF)
  • AIPLA Comments on the Third Draft Applicant Guidebook for New gTLDs, filed November 20, 2009 (PDF)
  • AIPLA Comments on the Second Draft Applicant Guidebook for New gTLDs, filed April 13, 2009 (PDF)
  • AIPLA Comments to ICANN on AGP Limits Policy, filed November 20, 2008 (PDF)
  • AIPLA Preliminary Comments on the Transition Action Plan, Improving Institutional Confidence in ICANN and FAQ prepared by the ICANN President’s Strategy Committee, filed July 31, 2008 (PDF)
  • AIPLA Comments on the restructuring of the GNSO Council, filed July 9, 2008 (PDF)
  • AIPLA Comments on the GNSO Council’s “Approved Motion on Domain Tasting," filed May 20, 2008 (PDF)
  • AIPLA Comments on the progress achieved by ICANN on the goals in the Joint Project Agreement between NTIA and ICANN, filed February 13, 2008 (PDF)
  • Comments of the American Intellectual Property Law Association to ICANN on the proposed changes to accessibility to WHOIS data, filed October 29, 2007 (PDF)
  • Comments of the American Intellectual Property Law Association on the WHOIS Task Force Preliminary Report (PDF)
  • AIPLA Comments on Combined Whois Task Force Preliminary Report (September 2005) (PDF)
  • AIPLA Comments on the Preliminary Reports of Whois Task Forces 1 and 2 (July 2004) (PDF)
  • AIPLA Comments on the Preliminary Reports of Whois Task Force 3 (July 2004) (PDF)
  • AIPLA Letter to ICANN re GNR Whois Proposal, November 17, 2002 (PDF)
  • AIPLA Comments to WI PO on the Second WIPO Internet Domain Name Process, April 12, 2001 (PDF)

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WIPO

  • Letter supporting the proposal by the United States of America and Japan to reduce the International Filing Fee and the Handling Fee under the Patent Cooperation Treaty by 15%, submitted September 6, 2007 (PDF)
  • AIPLA Comments on Search Strategy Recordation and Reporting of Statistical Information, filed January 2, 2006, with Mr. Francis Gurry, Deputy Director General, World Intellectual Property Organization (PDF)
  • AIPLA Comments on Supplementary International Searches, filed January 2, 2006 with Mr. Francis Gurry, Deputy Director General, World Intellectual Property Organization (PDF).

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EC Directives/Papers

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Comments on Hague (Jurisdiction/Judgement) Convention

  • AIPLA Comments to USPTO on the Hague Convention (Jurisdiction/Judgments), December 8, 2000 (PDF)

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Other International

  • AIPLA Comments on the Draft BSI PAS 98 Standards Consortia – Part I and Part II, July 20, 2010 . (PDF)
  • AIPLA Comments on National Standards Formulation and Revision Plan of Standardization Administration of China, the Disposal Rules for the Inclusion of Patents in National Standards, submitted March 1, 2010. (PDF)
  • AIPLA Comments to EPO on the Patentability of Computer Programs Case G 3/08, submitted April 28, 2009 (PDF)
  • AIPLA Comments on China Patent Law Implementing Regulations, submitted April 20, 2009 (PDF)
  • AIPLA Final Comments on the Draft Policy Recommendations and Report Formulated by the Japan Patent Office’s Policy Committee on Innovation and Intellectual Property, submitted July 11, 2008 (PDF)
  • AIPLA Preliminary Comments on the Draft Policy Recommendations and Report Formulated by the Japan Patent Office’s Policy Committee on Innovation and Intellectual Property, submitted June 26, 2008 (PDF)
  • AIPLA comments on the analysis entitled ‘Towards a Global Harmonization, High Transparency/Predictability, Promoting Innovation - Sophisticating the Pro-Patent Policy Responsive to Changes’ prepared by JPO’s Policy Committee on Innovation and Intellectual Property, submitted February 25, 2008 (PDF)
  • AIPLA Comments on (1) Singapore Treaty on the Law of Trademarks, (2) Geneva Act of the Hague Agreement Concerning the International Registration of Industrial Designs, and (3) Patent Law Treaty and Regulations Under the Patent law Treaty, submitted July 23, 2007 (PDF)
  • AIPLA in response to your letter of April 3, 2007 requesting information on fees for patent attorneys and on “diversified offices," submitted April 6, 2
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