USPTO New Strategic Plan (Draft)

The USPTO has released a draft version of its 2018-2022 Strategic Plan and is seeking comments before finalizing the document later this year.  The plan will serve as a key marker of Dir. Iancu’s strategic leadership.  Although a bit of a dog-and-pony show, the PTO Strategic Plan can serve as a single of where the agency is headed and can be used to help ensure that all key decisionmakers are on the same trajectory. If there is something that the PTO SHOULD be doing, now is the time to highlight that role.  Still, recognize that the value in most strategic plans is the learning process that occurs in developing that plan.  It is now your chance to participate — Send comments on the draft to Strategicplanning1@uspto.gov by September 20, 2018.

The Strategic Goals reflect the fact that the PTO is primarily a bureaucratic agency — and the main goal is quality bureaucracy.  That means efficient, correct, and timely work.  Thus, the PTO’s first strategic goal is “Issuing reliable IP rights.”

The goals:

  • Issuing reliable IP rights
  • Aligning patent and trademark examination capacity with current and projected workloads
  • Modernizing information technology (IT)
  • Enhancing the customer experience
  • Promoting a mission-oriented and quality-focused culture among our employees
  • Protecting IP rights abroad
  • Monitoring and helping address dynamic IP issues in Congress and in the Courts
  • Maintaining a sustainable funding model
  • Developing IP policy

The draft goes into some loose detail on the various issues that is fairly well summarized by the following tables:

168 thoughts on “USPTO New Strategic Plan (Draft)

  1. 13

    I do have to wonder what (if any) level of strategic planning experience the vast majority of those making comments on this thread have.

    There are many “Dilbertesque” moments here, many coming from this that appear to not have the foggiest idea on what “strategic planning” is. From “force-fitting” a “blame the applicant” undertone, to grousing about hurt feelings to dust-kicking on “conspiracies,” to attempts to include that which the Office does not control, all of these exhibit fundamental weaknesses on not understanding the basis of the document or its place as a management tool. The “Dilbert” aspect of “that sounds good and who could argue against that” falls flat when an understanding of what “strategic planning” is IS brought to bear.

  2. 12

    Improving search would help raise the quality of patents. Good attorneys want their applications allowed over the cited prior art.

    Lots of nonsense below–again the same old stuff.

    1) It is the job of the patent examiner to find the art not the applicant. The USPTO has the burden of examining the application and finding the best art. (Yes, there is a duty to disclose any art you may know about, but not a duty to know the best art.) The anti-patent movement is constantly trying to shift the burden to the applicant.

    2) The patents that are being invalidated with 103 at the PTAB, in general, should not be invalidated. There is the game of the “new” reference. Again, what we have is the anti-patent movement has come up with good propaganda to confuse the ignorant. The way it works is there are enormous numbers of possible references. The examiner may just pick the closest ones and not bother with cumulative references. All art in the field should be assumed to have been considered as the examiner could not go through all the art and is merely picking the closest. This is easy to understand when you know that there are thousands and thousands possible art references for almost all patents and when you understand what experts in fields do.

    3) What typical happens is that cumulative references are used with the same arguments that were considered by the examiner. Using KSR, the judges can invalidate any claim by saying it is obvious. Any claim. I could easily put together a 103 argument for any claim. So what you have is perfectly valid patents being invalidated using the same or similar arguments considered by the examiner but with different references that are equivalent. That is the typical case. There is no way the applicant can fight roll after roll of the KSR dice with “new”, i.e., another reference that is equivalent to one already considered.

    4) Alice is absurd. I can invalidate any claim (or present arguments to so) with Alice. Total joke.

    That is the current state of affairs. The anti-patent movement has all sorts of propaganda stories they run to try to obfuscate this.

    1. 12.1

      As to (1):

      If Applicants are sincere, in wanting the PTO to find the closest art, they would draft in line with PCT Rule 5(1), so that the PTO search can be properly focussed.

      In my experience, only those drafting inside the USA, and nobody else but them, deliberately choose NOT to draft in line with PCT Rule 5(1). For as long as they continue so to draft, the USPTO will be unable to deliver a “quality” search report and so unable to issue a “reliable” patent.

      For that drafting style though, I blame the courts, not the USPTO.

      As to (2) and (3):

      What is missing is a reliable and fair scheme of enquiry, to explore the obviousness issue. See Paul Cole. In Europe, the EPO is showing the courts how to “do” obviousness, reliably and fairly. The USPTO could follow Graham and then move on from there in EPO-PSA argument style. That would do obviousness reliably. Let the courts have their say on appeal.

      As to (4): Best if I don’t comment.

      1. 12.1.1

        If Applicants are sincere, in wanting the PTO to find the closest art, they would draft in line with PCT Rule 5(1), so that the PTO search can be properly focussed.

        Unbelievable Horse S H 1 T.

        You are aware that PCT Rule 5 claim drafting includes a call for the Jepson claim format, right?

        Are you that out of touch with how often (and why) the Jepson claim format is actually used?

        For as long as they continue so to draft, the USPTO will be unable to deliver a “quality” search report and so unable to issue a “reliable” patent.

        That’s the SECOND TIME on this thread that you have peddled that line. You provided NO substantiation the first time, and you do not offer any here as well.

        For that drafting style though, I blame the courts, not the USPTO.

        Ah, a glimmer of hope for some underlying reason from you. For the horse’s sake, let’s pray that this is not merely some mirage.

        Stop the proselytizing. At least, stop the feeble proselytizing.

        1. 12.1.1.1

          The only place in the world where you will find a Jepson-format claim is the USA. The only place in the world where you will find best practice drafting not in line with PCT Rule 5 is the USA.

          Try advancing a Jepson-format claim outside the USA one day, anon. See how far you can get with it, OK.

          And another thing, anon. Go re-read PCT Rule 5 with the specification in mind, as well as the claim. Remember Paul Cole’s advice in his book: the specification, and not the claim, is the place for describing the invention, the contribution to the art.

          1. 12.1.1.1.1

            What do you mean, Max? One is required to put the claim in Jepson format in Mexico. Nearly every MX office action ends with an admonition that the examiner expects you to amend the claim to Jepson format in the next response (although they never seem to penalize you when you ignore that admonition, until the claims reach the stage of allowability). I am told that they get this rule from Spain, although I have never prosecuted a Spanish national application, so I am uncertain of that last point.

            Mexico and Spain are—last I checked—places outside the U.S.

          2. 12.1.1.1.2

            A little further than Rule 5 (in Rule 6.3(b)):

            6.3 Manner of Claiming

            (b) Whenever appropriate, claims shall contain:

            (i) a statement indicating those technical features of the invention which are necessary for the definition of the claimed subject matter but which, in combination, are part of the prior art,

            (ii) a characterizing portion-preceded by the words “characterized in that,” “characterized by,” “wherein the improvement comprises,” or any other words to the same effect-stating concisely the technical features which, in combination with the features stated under (i), it is desired to protect.

            But “only in the US,” eh MaxDrei?

            1. 12.1.1.1.2.1

              I maintain that a PCT 2-part form of claim is not the same thing at all as a “Jepson” (the improvement comprising) format. That is a very common misconception in the USA. As I said, it is the US courts that have poisoned the Jepson format. I wonder how they would react to a patent properly drafted, and a claim correctly divided under the PCT Rules.

              Greg, may I ask, in Mexico, does the PTO want the claim in PCT or in Jepson form?

              1. 12.1.1.1.2.1.1

                Your “maintain” is meaningless on its face.

                Maybe do more than “maintain,” and distinguish them. Maybe provide a third party source that distinguishes them. But hey, maybe “your word” is enough.

                1. I think Greg should go first, and tell me about MX. Is it a PCT Rule 6 claim that MX wants, or is it really a Jepson.

                  Then I will reply to you both.

                  I should say that I’m obliged to you both, for prompting the thought: why don’t more PCT Member States ask for compliance with PCT Rule 6. My own guess is that it is because PCT Rule 6 drafting helps the PTO to search effectively and efficiently. After that, it is less important whether the claims that go to issue are in compliance with PCT Rule 6.

                2. Your “own guess” is in the weeds.

                  This is at least the third time that you have advanced a notion that somehow this format makes searching more effective and efficient, with no substantiation of the premise. No matter how you slice it, the claim – as a whole – still needs to be searched. Are you thinking that not all of the claim is to be searched?

              2. 12.1.1.1.2.1.2

                Sorry, Max, but I do not understand your question. What exactly is the difference between PCT 6.3 and Jepson format? They look the same to me.

                In any event, I agree with you about the courts “poisoning” the Jepson format. There is nothing intrinsically wrong with the idea of requiring the patentee to draft the claim to specify what the patentee perceives to be the advance over the art, but the U.S. courts have so badly corrupted the standard for obviousness that a Jepson claim is become an invitation to invalidation.

                Sort of the same way that the inequitable conduct case law has perversely incentivized the applicant to bury the examiner under a welter of irrelevant art. Bad law leads to bad outcomes.

                1. Greg, you put your finger on the difference. A Jepson form singles out the advance over “the art”. A PCT Rule 6 claim, by contrast, divides the technical features of the claim into two sets, relative to the disclosure of a single enabled embodiment in a single prior publication (D1) which could be as obscure as a PhD thesis in Russian, Chinese or whatever. I think this is why not only Jepson but also PCT Rule 6 claims are anathema in the USA.

                  But of course the extent of the “admission” by the Applicant is totally different. With a Jepson, one is admitting what is your “advance” over the art. With a Rule 6, one is admitting nothing more than what feature combination is disclosed by D1. Everything else is still in play.

                2. There is no “finger” there as the difference you attempt to distinguish is the SAME THING.

                  Your contrast is black on black.

                  Or white on white.

                  The admissions are the same because the structure of the claims are the same.

                3. Are you still there Greg? If so, what is your reaction, please, to my 36 mins past the hour posting of earlier today? In particular, do you agree with anon, that there is no difference between i) a typical Jepson claim and ii) a PCT Rule 6 (ie correctly divided EPO-style 2-part c-i-t) claim. That they are THE SAME THING. That:

                  “The admissions are the same because the structure of the claims are the same.”

                  I’m curious to know.

                4. Hi Max,

                  I confess that I am not clear on where in Rule 6 you find warrant for the idea that one is only supposed to distinguish over a single D1 document. If, however, we proceed on the assumption that PCT Rule 6 claims are different that Jepson claims because Jepson claims are supposed to distinguish over all the art, while PCT Rule 6 claims are only supposed to distinguish over a single, closest prior art document, then Mexico definitely requires Jepson.

                  That is to say, nearly every MX office action I have ever read has ended with an admonition that the claims are to be amended to make clear that which is in the prior art (all prior art), and that which the applicant regards as the novel bit. When the claims are eventually amended to conform to this requirement, they have all looked basically like Jepson claims to me.

                5. It makes no sense whatsoever to clear only a single piece of prior art.

                  MaxDrei is deep into the weeds.

                6. Thanks Greg. See PCT Rule 6 (b) (3) (1).

                  Do not overlook those magic words “in combination”. They are key. I think MX (like a great many other patent experts) has not appreciated their significance (unless, of course, MX Office Actions also mention the “in combination” concept of PCT Rule 6).

                  When it comes to novelty, and a D1 reference that includes a plurality of worked Examples, you can’t cherry-pick features from different ones of those Examples to erect a novelty attack. Key is the notion of “in combination”. If you have to”cherry pick” there is no such “combination”. So it is with PCT Rule 6 two-part claims.

                  No wonder a Jepson claim is despised. It is usually impossible to draft it correctly.

                  You see, once you remove the “in combination” constraint, you can usually find all features of the claim somewhere or other in the prior art universe. Almost invariably, a patentable invention is a new and inventive combination of technical features, each one in itself not new.

                  A PCT/EPO 2-part claim is only “appropriate” (to use the word in PCT Rule 6) when there is a realistic starting point reference (D1) within the prior art universe. Often there is not. And when that is the case, a 2-part form of claim is poison, also at the EPO. But when there is a realistic starting point in the art (for example, an earlier publication of Applicant), there is nothing better than a 2-parter to reveal to a an open-minded judge or jury not only that the claimed subject matter is novel but also that the contribution to the art which the claim encapsulates is plainly not obvious either.

                7. No wonder MaxDrei is so confused on this concept: there is an interesection with his confusion on obviousness (vis a vis the inconsistent treatment of PHOSITA.

                8. Beyond just blurring novelty and obviousness, MaxDrei makes the unsupported assertion of:

                  PCT/EPO 2-part claim is only “appropriate” (to use the word in PCT Rule 6) when there is a realistic starting point reference (D1) within the prior art universe. Often there is not.

                  There is ALWAYS a starting point reference.

                  Only God works from scratch.

                9. MaxDrei makes up out of whole cloth: “relative to the disclosure of a single enabled embodiment in a single prior publication (D1)” and “warns” of paying attention to “combination” in the PCT guidance while he misapplies “combination” himself. The “combination” in the PCT is clearly to feature and NOT to single or plural items of art.

                10. Once again I’m indebted to Greg and anon for their constructive questioning of the reliability of what I write. I see now that PCT Rule 6 had Jepson claims in view. But I am still curious about the difference I have experienced in real everyday practice, between a Jepson claim and a PCT Rule 6 claim.

                  In my experience, many US attorneys are not happy with a transition phrase “c-i-t” (or “the improvement comprising”) that correctly separates the features that are “in combination” within the prior art universe from those that reveal “the improvement” over the art. Instead, they want the transition phrase closer to the beginning of the claim.

                  Let us take a hypo. Your technical field is high carbon chrome bearing steels, and minor alloying elements in the composition. Your claim 1 is directed to a range of from 0.5 to 1.0% Mg. Claim 2 adds 0.25 to 0.5% Si. Claim 3 requires the molar ration of Mg to Si to be from 1.9 to 2.1. Why, because you have found out (and declare in your specification) that i) particles of Mg2Si in the microstructure improve the bearing function, but ii) a stoichiometric excess of Mg or Si has detrimental effects.

                  To your surprise and dismay (for you researched the state of the art thoroughly before you drafted claim 1, and you are yourself an out-and-out expert in the field), the USPTO cites D1, a PhD thesis in Japanese, catalogued and indexed 4 years ago in a public library in Tokyo, that discloses a HCC steel with Mg and Si in the alloy composition. Not only that, an Example in D1 destroys the novelty of claims 1 and 2 (but not 3). Fortunately, D1 says nothing about Mg2Si particles.

                  So, the patentability is relatively clear. How to write the claim under PCT Rule 6 is crystal clear. Nevertheless, my experience of how US attorneys write a Jepson would be: In a HCC bearing steel, the improvement which comprises…..

                  Plainly, such a division of the claim between its prior art and characterizing portions misrepresents what is the basis of its patentability over the art. At the EPO, for that reason, it would be rejected. We all agree that a Jepson would be foolhardy, but just suppose, for the sake of this discussion, that is what Applicant presents at the USPTO. What would be its fate there? In particular, would the PTO let it through to issue?

                  If so, that would explain the behaviour of US attorneys when instructing European counsel.

                11. But I am still curious about the difference I have experienced in real everyday practice,

                  Have to stop you right there MaxDrei. Your views on what you have experiences no doubt are steeped in your former mindset.

                  I suggest that you let the realization of just what the “Manner of Claiming” really is (and what THAT entails, given the differences in Sovereigns, including patent profanity created in the different Sovereigns) sink in for awhile. After you realize the points presented, approach this by remembering that how you have thought of this for awhile (probably decades) was flawed, and that the tendency of any conclusion of your past thinking is most probably in error.

    2. 12.2

      One suggestion to improve IPRs:

      make the petitioner submit evidence that the references being used are not cumulative compared with the references that were used to examine the patent.

    3. 12.3

      Re: the PTAB, I watched deliberations at an oral hearing for an IPR, 2 of the judges were asking questions that made it pretty obvious that they were coming from the position of “dear Patentee, the Petitioner has given us these references and says that they render your claim obvious. What are you going to do to save your patent?,” while the one remaining judge was dutifully trying to make the Petitioner ACTUALLY prove his case, instead of taking the Petitioner’s contentions as instantly true and shifting the burden to the Patentee.

      For all the supposed experience these APJs have, there is a serious misunderstanding by them of what burdens are and who bears them.

    4. 12.4

      KSR has nothing to do with “new references” versus “already considered references.” The standard in court is proving findings of fact by clear and convincing evidence. The standard at the PTAB is proving findings of fact by preponderance of evidence.
      I think you are discussing the “substantial new question of patentability” standard for instituting an Ex-Parte reexamination where it does not belong.

      1. 12.4.1

        PiKa: ? What?

        I am using KSR because KSR makes patentabilithy a roll of the dice. So what is happening is you get new references asserted against your patent claims that are cumulative and then it is just a roll of the dice whether the fact finders will find it obvious.

        The point is that KSR like Alice make it easy for any fact finder to invalidate any patent.

    5. 12.6

      Night Writer,

      As you can see by the several tangents in the replies to your post, the strategic plan FOR THE Office needs to ask the right questions so that the plan pertains to those things that the Office actually controls.

      The number one distinction is to make sure that “quality” is quality of examination as opposed to ANY notion of “quality patent.”

      The Office is not in any position to control the substantive nature of the inputs to the patent process and instead should be strategically built to be robust in its processing in order to deliver quality of examination OUTSIDE of the state of whatever inputs it receives.

      Anyone who has any appreciable experience in the real world with businesses that have “open inputs” can verify the veracity of my point.

    6. 12.7

      Perhaps you should consider a different perspective. (By the way, I’m not advocating a particular position. I am simply pointing out some thinks you may not have considered).

      “It is the job of the patent examiner to find the art not the applicant…. The anti-patent movement is constantly trying to shift the burden to the applicant.”
      Yes, but the relevant question is how to handle poor examination which will inevitably occur some of the time. Given the inevitability of examination failures, one must consider who is in the best position to avoid the issuance of invalid patents and who has the most incentive to avoid the issuance of invalid patents. Thus, while an applicant has no obligation to find the best prior art, as between the public and the applicant, the consequences of failure should arguably fall on the applicant. I assume you disagree, but this is a policy dispute–not a legal one.

      “The patents that are being invalidated with 103 at the PTAB, in general, should not be invalidated.”
      How would we quantify this beyond the assertion “in general”? While I have no doubt that you believe this, I think you presume too much by dismissing those that do not accept this as true. There will always be disagreement about whether any particular claims should have been invalidated. This disagreement may be grounded in different interpretations of 103 or different opinions of the relevant facts in a particular case. Simply dismissing those that disagree with you as being anti-patent is not persuasive.

      “The examiner may just pick the closest ones and not bother with cumulative references. All art in the field should be assumed to have been considered as the examiner could not go through all the art and is merely picking the closest.”
      Why should we make this assumption? There are other possibilities. The examiner may also have picked the simplest art–not necessarily the closest, may have missed something, or may have simply done a poor job. We don’t know. The issue that you seem to be glossing over is how to deal with this uncertainty. The use of an assumption is one of many possibilities. The consequences of a particular assumption are of profound significance, and are not self-evident.

      “This is easy to understand when you know that there are thousands and thousands possible art references for almost all patents and when you understand what experts in fields do.”
      Rather than support your assumption, this undercuts it. The greater the volume of potential prior art, the greater the likelihood that something was missed. Absent some indication in the file history, there is no way to know whether a given prior art reference was considered and dismissed as cumulative or not considered at all.

      “The anti-patent movement has all sorts of propaganda stories they run to try to obfuscate this.” While your conclusion may be correct, unsupported assumptions are not a rebuttal.

      1. 12.7.1

        the consequences of failure should arguably fall on the applicant.

        Pure B S.

        This IS a legal (as well as policy) dispute, and one that was settled in the Tafas case.

        Your own “frame of reference” is suspect, NSII.

        Remember – this is the strategic plan OF THE Office. You appear to want to make this something else entirely.

          1. 12.7.1.1.1

            So are you. That was fun.

            But then again, you do want everyone to take a “different perspective” and “blame the applicant”…

  3. 11

    Commentors on this blog persist in blaming examiners for the problem when there is abundant evidence that the PTAB is killing good patents that were thoroughly examined. Simply browse through the PTAB appeals at the CAFC and the vast majority were thoroughly examined with the same or cumulative prior art considered. Frequently the claims have been through multiple re-exams and IPRs as well.

    The hypothetical case of an examiner missing relevant prior art us simply not happening.

    U.S. patents ate not reliable because the AIA and PTAB procedures result in cancelling patents that were properly issued and compliant with the law.

      1. 11.1.1

        A patent issued with the best art known is not necessarily a proper patent.

        In absolute terms, sure. For the sake of the law, the presence (and level) of it BEING proper have been provided.

        Those provisions notable were not changed with the AIA.

    1. 11.2

      Simply browse through the PTAB appeals at the CAFC and the vast majority were thoroughly examined with the same or cumulative prior art considered.

      Given how many of these AIA trial appeals are Rule 36’ed, I cannot understand how “browsing” the appeals decisions would give one a reliable insight into what happened at the PTAB. If you have done a systematic study on this point, I would be interested to read it. If you are merely cherry picking cases, however, then your assertion deserves rather little credit.

      Incidentally, I would note that the vast majority of IPR petitions end with no claims affected. The AIA trial cases that end with the CAFC pronouncing invalidity are a minority of a minority of a minority, and hardly a representative sample.

      U.S. patents ate not reliable because the AIA and PTAB procedures result in cancelling patents that were properly issued and compliant with the law.

      How does this conclusion jibe with your premise stated above (that the CAFC is pronouncing claims invalid over art cited during prosecution)? If the CAFC thinks that the claim is invalid, then (almost by definition) the claim is invalid. If that claim falls over art cited during prosecution, that is actually evidence of sub-standard examination, not evidence that examination is just fine.

      1. 11.2.1

        Yes Greg, the phony alleged statistic that most granted IPRs merely re-hash only prior art previously cited by examiners to reject the patent claims has been now repeated so often it has acquired a false news life of its own. No actual such study result is ever reported. It is not even logical for any competent IPR petitioners to do that.

        1. 11.2.1.1

          has been now repeated so often it has acquired a false news life of its own

          Please feel free to turn that same exact spotlight on the loads of Rah-Rah IPR cheerleading (and other anti-patent) rhetoric.

      2. 11.2.2

        I have lived it. And read many of the records if other devastated inventors. I am not talking about the decision at the CAFC – they rarely address this issue. It wasn’t even argued for the first 4 years of IPRs. Only in the past year or so did lawyers start advocating for 325(d) at the PTAB so you won’t see that addressed in Fed Circuit decisions, Rule 36 or otherwise.

        You have to look up the FWD to identify the prior art then compare it to the references listed on the patent.

        Even then, if you are advocating Telelebrands and other infringers you will just say the examiner “did not consider the references in a meaningful way” or your “newly discovered” references are “closer prior art”. If you want to believe in the PTAB there are plenty of ways to clinch your eyes shut and excuse what they have done.

        1. 11.2.2.1

          I am not talking about the decision at the CAFC…

          Um, begging your pardon, but go re-read your own post #11. You invite us to “browse through the PTAB appeals at the CAFC” as evidence for the thesis you are advancing. If, as you now say, you are not relying on CAFC decisions to support your thesis, then you have literally no evidence behind your assertion, except for your own personal experience (a point which only may or may not be representative). A generalization from such a small sample is—forgive me—rather unconvincing.

          I happen to think that your own invention got a raw deal in front of the PTAB. Of course, the CAFC recently sided with you, so it is not clear that your experience stands as evidence that the system as a whole is failing. One way or the other, before one can talk about “excusing” the PTAB, one must first establish that they are broadly in the wrong, and so far this is just an ipse dixit unsubstantiated assertion on this record.

      3. 11.2.3

        Greg,
        Incidentally I would note that your reliance on that 2015 report is highly misplaced. The flawed methodology that equates a settlement which results in the dismissal of the petition without a decision as a “Win” by the patent owner is highly misleading. EVERY settlement after an IPR is filed results in some sort of loss to the patent owner from the previous position of firm property….whether in terms of risk, money, time, or reputation damage to the patent. While the claims might survive…the value of the patent (and its claims) are very visible diminished. Given this combined 32% (pre- and post-institution settlement) is enough to swing the # of negative “outcomes” of the IPRs to patent owners into the majority column…your argument falls apart.

        Not surprising that the statistical counting methodology used by Lex Machina misrepresents the negative outcomes to patent owners since the firm was founded by the father of “efficient infringement”, Stanford professor Mark Lemley….whose legal and consulting clients include Google…and whose wife was Google’s Chief Trademark Counsel from 2004-2010.

        1. 11.2.3.1

          I see two lines of response there. Taking them each in turn:

          (1) One cannot trust anything that LexMachina says because Mark Lemley is involved with it. Fair enough. If you think that those numbers are all just vaporous invention, there is nothing more to be said on the subject. I would note, however, that the conclusion that the overwhelming majority of claims challenged come out totally unscathed is also supported by the PTO’s own data.

          (2) Settlement is still a loss for the patentee. This seems to me like a “how many angels can dance on the head of a pin?” question. Each settlement is its own unique snowflake, and it is impossible to know whether the patentee regards any given settlement as a “win” or a “loss.” I only mentioned that the claims come through unaltered, which is true.

          Whether this outcome is subjectively desirable to the patentee is a point on which I never opined, mostly because I know little and care less on this point. It is possible that you care more than I do about this point, but I doubt that you know any more than I do about any but a handful of those settlements, so there is not much room for productive discussion here.

        2. 11.2.3.2

          ? The statistics are readily publicly available that settlement agreements between the parties account for a relatively small percentage of IPR terminations. [Not to be confused with D.C. patent suits where they account for the large majority of terminations.]

    2. 11.3

      abundant evidence that the PTAB is killing good patents

      LOL

      Where is this “abundant evidence”? Behind Ron Katznelson’s couch cushions?

      Nobody’s suggesting that the PTAB is perfect (human beings, after all) but the “de@th p@nel” nonsense was always nonsense. But you bought it hook, line and sinker, didn’t you?

      Sad.

    3. 11.4

      Frequently the claims have been through multiple re-exams and IPRs as well.

      So. What.

      All it takes is the right art and an attorney who is skilled at presenting the arguments relating that art to the claims in the most compelling manner. It may come as a surprise to you but sometimes people taking advantage of re-exams and IPRs don’t hire the best attorneys. Sometimes they hire their friends instead.

    4. 11.5

      the AIA and PTAB procedures result in cancelling patents that were properly issued and compliant with the law.

      The whole truth is that most patents that are cancelled by the AIA and the PTAB deserve to be cancelled and should never have issued. This doesn’t address the fact that a lot of cr @p patents don’t even make it through the system because the owner knows that the patent is cr @p and therefore doesn’t behave like a greedy disgusting p i g when trying to “monetize” it.

      This is exactly why the AIA was passed by the way. Do you not remember the greedy p i g s? Happy to name names, if you need a refresher. It wasn’t that long ago.

        1. 11.6.1.1

          It’s almost as though you can’t stand the thought that someone (1) disagrees with you, and (2) has a VERY prominent blog with a large following of people that ALSO disagree with you. How’s your special MM blog doing these days? I can see why you’re frustrated. You know what they say, if you can’t figure out who the sucker is (or in your case, if you think that everyone else BUT you is the sucker), you’re it.

  4. 10

    Expunge logic patents from the system and return the PTO’s focus to innovations with objective structures and structural consequences (as opposed to vaporous data-processing g@r b@ge) and just about all these “reliability” problems will disappear.

    Plus it’s the legally correct thing to do.

    You don’t fix a broken t0 i let without plunging the shirt out of it first.

      1. 10.1.1

        return to those iron age inventions back when things were great

        Yes, trains and subways are great.

  5. 9

    1. Shut down the Patent Office and go to a Patent Registration system handled by the Copyright Office. Most (maybe all) of the important patents are litigated anyway. It will end the current abominable mess of allowing companies to attack a patent on two fronts with two different standards for interpreting claims. The Patent Registration fee should be about $50.

    Another reason for doing this is that the Copyright Office does not seem to have a problem keeping their computers running. And I don’t think the Patent Office is telling us the truth about why their system stopped working. It sounds like a case of ransonware which which is why they had to apparently regenerate the database from scratch using very old backups, which is why people are getting email NOAs several years old.

    2. End the discrimination against NPEs. If an Article III court has determined that a company’s product is infringing your patent you should have the right to prevent that company from making, using, or selling that product in the United States. Of course this requires an Act of Congress (and I don’t mean sex).

    Either that or change the language on the cover of the ribbon copy because, as it stands, it is fraudulent.

    And why aren’t companies that have a patent that is not used in even one of their products considered a NPE for that patent?

    3. At the very least, require that patent examiners take and pass the very same Registration Examination that patent attorneys and agents have to take, not the watered-down test which is mostly about being able to find the bathrooms. Patent examiners should also have to be ATTORNEYS since their decisions are given immense authority by Article III courts.

    1. 9.1

      End the discrimination against NPEs. If an Article III court has determined that a company’s product is infringing your patent you should have the right to prevent that company from making, using, or selling that product in the United States.

      I do not really disagree with you, but how is this a worthwhile performance goal for the PTO? The PTO does not adjudicate infringement. It only grants (or revokes) patents.

      I see no evidence that it treats NPEs differently from PEs. At the time that one is in the application prosecution stage, almost all applicants are NPEs.

    2. 9.3

      Shut down the Patent Office and go to a Patent Registration system handled by the Copyright Office. Most (maybe all) of the important patents are litigated anyway. It will end the current abominable mess of allowing companies to attack a patent on two fronts with two different standards for interpreting claims.

      ROTFLMAO Oh noes! Two fronts! It’s abominbabblbibble! Waaahh!! Waah!

      End the discrimination against NPEs.

      “Discrimination”? LOLOLOLOLOLOL Poor widdle NPEs. Life is soooooo unfair if you’re a non-practicing entity trying to “monetize” some g@ rb@ ge patent. Waahh! Waah! Leave those poor widdle NPEs alooooone!!

      why aren’t companies that have a patent that is not used in even one of their products considered a NPE for that patent?

      Who says they aren’t?

      Patent examiners should also have to be ATTORNEYS

      Okay. Let’s get rid of patent agents, too. [shrugs] This will change everything! LOL

      1. 9.3.1

        Malcolm, I am trying to find something (anything) other than ad hominem in your reply and find nothing at all on point or of merit in reply to the suggestions.

        Other than such (empty) feelings, can you offer anything as to why (or why not) such suggestions should be considered? Can you offer ANY considerations on the merits?

    3. 9.4

      “1. Shut down the Patent Office and go to a Patent Registration system”

      To me this seems like the only realistic solution to the Office’s qualit- er, reliability issues. If the examination process doesn’t produce grants that deserve a presumption of validity, and if the applicant community isn’t willing to pay enough to fund a system that produces grants that deserve a presumption of validity, then just cut out the examination. The downsides of a functional registration system are less than a broken examination system.

      1. 9.4.1

        The U.S. already tried that with the Patent Act of 1793. The result was low quality patents and endless litigation. At least with patent examination, most of the truly undeserving stuff never gets patented (or are never even applied for), and those that do get patented tend to have more clearly defined scope and content of claims than they might otherwise. Examination was restored with the Patent Act of 1836.

        Also, with a pure registration system, patent applicants would need to supply a much larger claim set just to survive litigation with at least some claims intact.

        Perhaps a better approach to no examination at all would be deferred examination, like that used in many Asian countries. Of course, that too would take an act of Congress, and so is not the proper subject of the current draft strategic plan.

        1. 9.4.1.2

          I frequently find myself thinking something like Ben’s 9.4, but in the end I think that Mark’s 9.4.1 has the better of this dispute.

        2. 9.4.1.3

          I am aware that we previously had a registration system. It’s clear that an examination system was superior to registration around 1840. That fact does not mean that it is superior today. Given the political realities of our federal workforce, the vast expansion in amount of prior art, and the problems with examining hughly functional claims, it is not clear to me that examination remains superior.

          I don’t see how any problems with registration can overcome the problems of an examination system with broken examination.

          1. 9.4.1.3.1

            There is “broken” and then there is broken. You see only the problems that result when a patent grants that ought not to have granted, but for the failure to spot some pertinent art. You do not see the problems that would have resulted if no examination were performed at all, and anyone could get to grant on any claim at all. If we do away with examination, however, we will get to see such problems, and my expectation is that they will be numerous.

            Basically, in a jurisdiction with the “American rule” (and the U.S., as you might expect, has the American rule), the cost of defending against a wrongfully granted patent is born by the one wrongfully accused. This is intuitively undesirable, so we make the one seeking a patent bear at least some of the costs of preventing the wrongfully granted patent by forcing the applicant to pay for some measure of examination as a necessary precondition to receiving a document that can be used as the basis for a lawsuit. This at least weeds out the most egregious cases of wrongful patent grants, and thus prevents the most conscience-shocking occasions of forcing the innocent party to pay legal fees to defend against a meritless suit.

            I can see the intuitive sense of a registration system in a world where examination is so palpably imperfect. My Bayesian priors, however, are to expect that if we were to do away with examination, we would find out that—imperfect though it might be—the current examination regime is (literally) better than nothing.

            At the very least, if we were to do away with examination and switch to a pure registration system, we should also statutorily suspend the “American rule” for patent suits.

            1. 9.4.1.3.1.1

              … the cost of defending against a wrongfully granted patent is born by…

              Er, “… the cost of defending against a wrongfully granted patent is borne by… .” Mea culpa.

        1. 9.4.2.1

          Software is not literature and the differences in aspect as to what the different IP laws cover is more than enough to toss your statement into the trash can.

          That line about “cannot examine” was wrong when it was floated in the 1960’s. It is still wrong today.

    4. 9.5

      If an Article III court has determined that a company’s product is infringing your patent you should have the right to prevent that company from making, using, or selling that product in the United States.

      Why? It is not that I am disagreeing with you as a matter of policy, but how things should be doesn’t work as a premise.

      Either that or change the language on the cover of the ribbon copy because, as it stands, it is fraudulent.

      I wouldn’t say fraudulent, but it is certainly misleading because the “right to exclude” depends on the circumstances in a way that is not readily apparent to the general public.

      1. 9.5.1

        the “right to exclude” depends on the circumstances in a way that is not readily apparent to the general public

        Pretty sure that the “general public” wants to be able to think about correlations without fear of being sued by some sc u m b@g patent attorney who has so much free time on his hands that he can whine on a patent blog about some “right to exclude” being “fraudulent”.

        You guys really crack me up sometimes.

      2. 9.5.2

        but how things should be doesn’t work as a premise.

        Read that again.
        Slowly.
        Out loud.

  6. 8

    Unrelated, but Ex parte Jung has been de-designated as “informative” by the PTAB:

    link to b2ipreport.com

    The de-designation was the correct decision and serves as unspoken recognition that the decision was faulty in the first place because the Board cannot, as a matter of law, choose, between two claim constructions, one supported by the specification and one not, the claim construction that is not supported by the specification, because even during prosecution a claim must be interpreted as it would by a person skilled in the art in view of the specification.

    1. 8.1

      Thank you for confirming that Jung was misunderstood. Sometimes, as a matter of law, claims are not enabled and/or lack adequate written description support. Even under a more stringent Phillips construction.

      1. 8.1.1

        More than sure that THAT was not the problem with Jung.

        You do recognize the “1984” essence of the government statement, right?

    2. 8.2

      “[E]ven during prosecution”? What the f are you talking about? Any attorney in favor of the client’s interest would be grateful that somebody at the PTO pointed out that the specification failed to support the plain and ordinary meaning of the claims and, further, gave the client the right to enter an amendment resulting in stronger claims.

      1. 8.2.1

        You are barking up the wrong tree, historical moniker user without a clue.

        Do you know what the Jung case was even about?

    3. 8.3

      Yes, perhaps the Jung decision was a bit too subtle for, uh, was a bit too subtle. Read what Pauline said about the goal and reason for patent prosecution in In re Zletz. Resist the newby reflex of ‘I can distinguish that case.’ Listen to Pauline. She is talking.

      1. 8.3.1

        If you think that something that Judge Newman said in In re Kletz intersects with the Jung case, why not just tell us what you think that THAT is?

        As is, Jung was horrible, was horribly promoted, and is now being “1984’d” in its deserving demotion.

        But hey, I’m all ears for your alternative view.

        1. 8.3.1.1

          Somebody asked me, what are you talking about? In re what?

          But you have a convincing argument. Everybody should have a patent. Here’s one for you, and you, and you. And because you’re so nice, here’s two for you.

          1. 8.3.1.1.1

            How is your reply even pertinent to the conversation?

            You seem to be generating a strawman (“patents are nice, so everyone gets one – no Quid Pro Quo required”) only to impliedly knock that strawman down.

            NO ONE is arguing for“free patents for everyone,” and that view is a non sequitur to the conversation point here.

            Do you have a view that is on point?

                1. The point, dear “Historical Pseudonym,” is that YOU are being asked to explain the pertinence of your post at 8.3.1.1 – there is nothing (yet) FOR me to “explain,” so your rather inane accusation is simply (yet another) non sequitur.

                2. Your view of “bested” only fits on opposite day.

                  As it stands, you were asked to explain something and apparently cannot, and thus you revert to mindless gamesmanship.

                  There’s a bit of this “troll-like” behavior going on and it is somewhat amusing to think that the mindless posts are doing anything but damage to those trying this tactic against me.

                  Say “le vee.”

  7. 7

    If the subject here is specific action item suggestions for PTO improvements going forward I do not see many in the 29 below so far.
    I wonder if the latest PTO software/server disaster is at least partially related to user-overload of Public Pair? [Including search engines.] If so, since it is public information, why not have the PTO pay to move Public Pair off to a major cloud service provider that can handle it?
    A related concern is one I had asked about years ago but never received adequate assurance. It is the vital protection of the vast amounts of major new U.S. and foreign technology and commercial lead times in all the yet-unpublished patent applications in PTO Private Pair and elsewhere, and the identity of their sources. [More than in any other database.] Given the massive extent of successful hacking of other supposedly-secure U.S. government and industry data sites, and the extensive efforts of certain foreign governments in industrial espionage [even France], this should be a very high PTO IT priority.

  8. 6

    I think part of the strategic plan should consider the substance of this.

    One of the “Examining Corp”—

    You sound like a typical government employee. No you don’t make as much as we do. You work about 1/2 as hard as we do and you did about 1/2 as well as we did in school and in jobs. The PTO has a very high retention rate. Attorneys doing prosecution in private practice have a low retention rate and are constantly fired.

    Our job is much, much harder than yours and overall we are much smarter and harder working than you. I know many attorneys that left private practice and work at the PTO. They say it is a cake walk. No you don’t get paid much but the work is steady and isn’t very hard. I know the PTO very well. I go and have lunch there sometimes with old friends who used to work at some of the best law firms in the country but decided it was way too hard. (And it is.) And I grew-up not far from the PTO.

    You are like all those government employees that overrate how hard they work and overrate their own skill set. I grew-up in DC and the government worker mindset very well. Many relatives that are lifers for the federal government. All of you think that you are worth just so much more and if only you weren’t working for the government, why you’d be a CEO or Nobel Laureate. The fact is you are just a bunch of average joes and janes that don’t work very hard and get a decent wage. Nothing wrong with that, but pretending you are something else is ridiculous.
    And anyone that doesn’t have their head up their a$$ knows what I wrote is correct. And let’s not forget that you have a union. Or that examiners regularly take a month off. I don’t think I have ever known an attorney at one of the top firms take a whole month off. Or that many of you go to work and leave at 3:30 to pick up kids and that is it for the day.

    Etc. You don’t work that hard. You aren’t that smart or skilled. Get 10,000 of you together and you can make each other believe that you are poor overworked geniuses that deserve much more. What a joke.

    The biggest difference between our jobs is that we are paid by corporations that constantly try to squeeze more out of us and pay us less. The average application now is maybe $10k (and probably less for many clients) when 10 years ago it was more like $14k. That is a fairly conservative estimate. Some apps have gone down to $6k and 10 years ago you could still get $18K for an app.

    You work for the government and when you need more money you jack up our fees which puts more pressure on our pay.

    In fact, it is getting hard to find people that want to be patent attorneys for good reason. The work is up from 10 years ago and the pay is down. And all indications are that it is going to get worse for two reasons: 1) corporations are gaining more and more power and thus have more leverage over us; and 2) patents continue to weaken and are seen as almost junk at this point. Corporations are saying we don’t really want to pay for this junk and maybe we should cut back budgets.

    So please government worker don’t whine to me.

      1. 6.1.1

        Really a conspiracy theorist? Sounds like you are one and one of those people that dismiss people with insults.

        1. 6.1.1.1

          Considering you insulted the examining corps repeatedly, it’s all the response you deserve.

      2. 6.1.2

        “A conspiracy theorist” really bothers me because it discounts the evidence I post on this blog. What I’ve noticed is the anti-patent group are unethical. They pretend they haven’t seen the evidence and request it be re-posted constantly. For example, there have been several articles that detail the extent to which Google has influenced IP law at the federal level and in many other ways, e.g., paying law professors to write journal articles and pretend they are scholarly works. Etc. There has been evidence of Google visiting the White House on an almost daily basis and influencing or selecting the PTO director and judges.

        When I was a young man, people like you that act so unethically (like Lemley too) were dismissed and shunned. Now it seems that you just float over your unethical conduct and continue on. Your type of person is really a big part of the problem. We need for their to be consequences for unethical behavior.

        1. 6.1.2.1

          Your most consistent point is that the messenger destroys the message. Well… you’ve destroyed the message and no one can put stock in anything you have posted.

          As a side note, what are your thoughts about lands wars in Asian? Be cause you keep on using a word but it does not seems to mean what you think it means.

            1. 6.1.2.1.2.1

              Yes, the person skeptical of the conspiracy theory is the one with mental health issue.

              1. 6.1.2.1.2.1.1

                “Conspiracy theory”: Please point to one of my posts that you would characterize me advancing a “conspiracy theory”.

                1. Any post in which you discuss Judge Reyna, President Obama, or Director Lee.

        2. 6.1.2.2

          “A conspiracy theorist” really bothers me because it discounts the evidence I post on this blog.

          LOLOLOLOLOLOLOLOLOLOLOLOLOLOLOLOLOLOLOL

        3. 6.1.2.3

          When I was a young man

          Get ready, folks. Bitter white grandpa is going to tell one of his famous tales.

    1. 6.2

      Night Writer,

      I “get” your feelings (and the basis for those feelings), but how is it that you view that such could be considered as substance to be a part of the strategic plan?

      Are you talking about an attitude adjustment? Removing the “bureaucrat mindset” from the bureaucrat?

      1. 6.2.1

        Substantive part is a realization that domestic patents are in a decline and that the value of patents has decreased by 80 percent over the last 10 years.

        Additionally, that fewer applications are accounting for more of the patent applications domestically.

        Additionally, that ramping up maintenance fees may be directly related to other budgets and it is not just free way to make more money. There may be relationship between raising maintenance fees and budgets for filing patent applications.

        Additionally, the PTO should plan for a potential drop in patent applications domestically of 20-40 percent in the next recession.

        Certainly those are macro trends that should be considered.

        1. 6.2.1.1

          Substantive part is a realization that domestic patents are in a decline and that the value of patents has decreased by 80 percent over the last 10 years.

          That’s a different topic than the one I am asking about (and the one you posted at 6).

          1. 6.2.1.1.1

            Not really. The PTO should be anticipating a possible disruption and should be trying to learn to do their job with far less money.

            They have to realize that their product the patent is now worth only 20 percent of what it was pre-AIA.

          2. 6.2.1.1.2

            (I see the connection to the second part of your post at 6 – I meant how to tie to the first part)

        2. 6.2.1.2

          Substantive part is a realization that domestic patents are in a decline and that the value of patents has decreased by 80 percent over the last 10 years.

          Is there some metric we might use to determine the appropriate valuation of domestic patents?

          1. 6.2.1.2.1

            That is an excellent question.

            A follow up of course may well be – are there accepted (official) accounting standards that properly reflect not only the value of such assets but how that value may change based on such things as Court cases and changes in statutory law.

      2. 6.2.2

        Patents should be seen as on the ropes. Another big negative decision or piece of legislation and many corporations may cut their budgets by 80 percent for patents.

        I am seeing this now, by the way. I see huge corporations that have cut patent budgets as much as 50 % in some divisions.

        1. 6.2.2.1

          many corporations may cut their budgets by 80 percent for patents.

          Many corporations should be doing that now. Many corporations should never have gotten into the patent game because it’s a waste of their resources. It’s not a waste because “patents are weak”. It’s a waste because their business model doesn’t need patents to succeed and the money spent on patents and patent lawyers could be spent on far, far more profitable ventures.

          In the grown-up arts, we advise our clients all the time that it’s not worth filing patents on everything. Of course, you need to be somewhat successful at what you do to enjoy the luxury of telling your clients the truth in this business (or so it seems). If you’re desperate for cash then, heck, just keep filing away. Don’t forget to patent the method of calling your attorney to tell him/her about the “innovation”, or asking a question about it. Everything’s on the table! Money, money, money, money and nothing else matters. Let’s patent methods of thinking new thoughts about correlations! What could possibly go wrong?

    2. 6.3

      Assuming that you correct about the disparity between private patent attorneys and patent examiners, wouldn’t the solution be to have some sort of adversarial system between private patent attorneys to account for the deficiencies of patent examiners?

      1. 6.3.1

        What about having applicants use their representation examine patents? The representation does a search of the prior art and writes up why the invention is allowable over references A through H (much in the way accelerated examination presently works). A super-legal-instruments-examiner (read: much less generously paid patent examiner) reviews the case for formalities and thoroughness. Then the issued patent gets a presumption of validity, but only against the references A through H.

        1. 6.3.1.1

          That was the (hidden) intention of the disqualified (as in illegal) rules changes awhile back that included the ESD (express su i c1de document).

        2. 6.3.1.2

          Interesting. This would encourage greater front-end investment in patents expected to be valuable. As long as there was still some type of cursory novelty/obviousness examination to weed out anything truly egregious, this could potentially work.

          1. 6.3.1.2.1

            Ever hear of “Sport of Kings?”

            Your “let’s make the front end investment level necessarily higher” plays right into that.

            That’s the opposite of the intent of the US patent system, by the way. That makes competition = f (landed money) as opposed to competition = f (disruptive innovation).

      2. 6.3.2

        have some sort of adversarial system between private patent attorneys

        You mean, besides the existing one of an open marketplace wherein clients are free to go where they please?

        It appears rare indeed that you actually think before you simply type away.

        1. 6.3.2.1

          Were you trying to hurt my feelings? If so, have you considered the possibility that you are simply frustrated by the low value of your opinions? If not, you should consider why your opinions are of low value.

          It is a shame that arrogant ignorance cannot be self-diagnosed.

          1. 6.3.2.1.1

            Multiple misses – each of which by miles.

            It is mighty “arrogant ignorance” of you to label my views (opinions) as low value.

            Frankly, NSII, with the caliber of your posting, that YOU think them to be “low value” means that they are high value.

            So thank you for that.

    3. 6.4

      Wow! I bet you’re a real delight to have around at parties and during the holidays.

      You’re not wrong about the fact that the job of examiners is easier, as a lawyer who previously practiced law and a current examiner I can attest to that. However, lets be real here, your statement about “1/2 as well as we did in school and in jobs” is absurdly incorrect. A large percentage of examiners have masters, PhDs, or JDs. The typical patent attorney at the large sweatshop firms (you know who you are), is producing no better work product than the typical examiner. The attorney is paid slightly more when the government retirement package for examiners is factored in, but has to deal with clients and has to work longer hours. The examiner gets paid well, has a very flexible work schedule, in general works less hours, and the job is far more secure.

  9. 5

    I’m told at 1.2 that “reliable” is code for “harder to challenge”. Even if that is so, does it not beg the question, what does “harder” mean?

    One meaning would be “harder to find a ground of invalidity that will succeed”. That is extraordinarily (US unique) tough already, what with the C+C evidential burden on the challenger. Can it be made yet “harder”?

    But another would be “harder to get into a forum where my well-founded ground of invalidity will get a fair hearing”. Is that really what the USPTO thinks is needed?

    The ordinary meaning of “reliable”implies “trust”. In rock-climbing, a reliable foot hold is one you can trust. So, a “reliable” patent is presumably one that its owner can trust, to deliver its expensively paid-for function, even in the face of adversity ie hold up when asserted against an infringer.

    It’s as simple as that, isn’t it?

    and, if not, what do others think is a “reliable” patent?

    1. 5.1

      See the comment below about focusing on what the Office controls. How then does your point here on “trust” translate? What generates “trust” in the internals of the Office?

      An important part of any strategic plan is identifying what is, what can be, and what should be controlled – what the focus of efforts should be on.

      Paul Cole is correct to a very real extent that “quality patent” is outside of the strategic control of the Office. Our innovation engine has NEVER attempted control of the input in a substantive manner (and only in matters of form).

      Here (again) our Sovereign has a separation of powers notion and the Executive Branch administrative agency should have as its focus how it can best make sure that it is doing best those things that it controls.

      1. 5.1.1

        On “trust” I was primarily thinking about the “quality” of the USPTO search. The better that quality, the more confidence one can draw, that the claims have issued over what is, in fact, the closest prior art.

        My experience is with cases getting searched by the EPO, after EPO national phase entry, after the USPTO has performed as ISA.

        Time and again, the closest art in examination is something which the EPO search found, and the USPTO search did not.

        How “reliable” then, is that USPTO search? How much can you trust it, to have brought the closest art to light?

        1. 5.1.1.1

          primarily thinking about the “quality” of the USPTO search.

          Fair enough – and well within what the Office controls.

          1. 5.1.1.1.1

            Except that it is hard to do an effective job searching subject matter which lacks adequate “written description” support. What is “adequate”? See Paul’s PCT Rule 5.

            Is that judgement of adequacy within the control of the Office?

            1. 5.1.1.1.1.1

              You advance a premise without substantiation.

              Why exactly is it “hard” to do an effective search on <i)whatever it is that is submitted?

              Do not cloud that which cannot be controlled with that which can be controlled. That is merely obfuscation and a sure fire way to not reach a strategic goal.

        2. 5.1.1.2

          “after the USPTO has performed as ISA.”
          I believe the USPTO does not perform many searches as ISA; the USPTO contracts most, if not all, of the ISA searches out.

          1. 5.1.1.2.1

            I believe the USPTO does not perform many searches as ISA; the USPTO contracts most, if not all, of the ISA searches out.

            This is a strange distinction to make. A principal is responsible for the acts of the agent. If the PTO is contracting out the searches for cases where the PTO is the ISA, and the contractor does a poor job, that is much as to say that the PTO is doing a poor job as an ISA.

            1. 5.1.1.2.1.1

              Agreed, but in light of Night Writer’s comments, it should be clear that the “examining core” are not the ones doing the searching

              1. 5.1.1.2.1.1.1

                Er, once again, if the international phase searches at the USPTO are being done by contractors, that is simply as much as to say a substantial chunk of the “examining corps” are contractors. The cossacks work for the Czar.

        3. 5.1.1.4

          Max, by now you must realize how many of the folks complaining about US patent quality here would also be the first to complain if the US PTO started charging the kind of application examination fees that the EPO does. For those prices of course many EPO searches are better searches.

          1. 5.1.1.4.1

            EPO Examiners are given quite a bit more time to search, if memory serves right close to 50% more time than USPTO Examiners, and they typically only reject the independent claim.

    2. 5.2

      Max, re “what do others think is a “reliable” patent?” depends to a large extent on how much time & money one is willing to put into it. Considering the low fees of U.S. patents before issuance compared to other major countries, a patent that can at least survive initial claim and file reviews and a moderate-cost prior art search would be a good start. But U.S. examiners are time-restricted to inadequate prior art searches in most cases, especially with searchable prior art more than doubling every ten years, and the US PTO does not check prior art search accuracy or thoroughness in its quality reviews.

  10. 4

    This is Dilbert material (e.g. “optimize performance culture”). Most of these bullet points could have pulled out of a first year M.B.A. student’s PowerPoint on how to improve a fictional pencil company.

  11. 3

    New and constructive leadership is greatly to be welcomed.

    It bears repeating that patent quality is primarily a matter for inventors and patent attorneys working as a team, and although the USPTO examiners serve an invaluable function as referees (by analogy with publication of papers in scientific journals) they can improve but cannot add to the disclosure contained in the original patent specification. The whole edifice of prosecution, international applications, licensing and possibly litigation stands or falls on the quality of that original document, often nowadays drafted under corporate budgetary pressure but nevertheless providing a foundation which deserves resources and should be made as sound as possible.

    Reliability will always be an elusive goal. In prosecution perhaps $10,000-30,000 will foreseeably be spent in drafting the application and prosecution through to grant. If litigation comes, the resources of each side are more likely to be in the range $1,000,000 – 3,000,000. The candle of the original disclosure is overwhelmed by the searchlight of the litigation. It would be astonishing if, in almost every case, additional prior art and more arguments are not identified. Examiner training and good work product are to be encouraged, but the USPTO should not be criticised by reflex if an issued patent turns out to be invalid.

    Reaching out to our profession and international collaboration are to be greatly encouraged. More internal research e.g. on the contentious issues of Section 101 would be helpful and in appropriate cases amicus briefs.

    1. 3.1

      Paul, your reply indicates two things:

      1) you are correct that the notion of “a quality patent” depends to no small degree on the quality of the input, and

      2) the Office does NOT control that element.

      The takeaway though is LESS the focus you push and MORE a different phrasing for the strategic plan OF THE Office: “examination quality” instead of “patent quality.”

      Examination IS 100% controllable by the Office.

      Inputs are not, and to a certain degree, should not, be the focus OF THE Office. Focus on inputs, something the Office does not control just turns into a “blame the applicant” game, and averts attention from what the Office does control.

      Several of the resident “maximalists” here recently remarked that quality examination is what we want.

      It is still what we want – regardless of the separate quality of input. If we are talking about the strategic plan OF THE Office, let’s keep the focus on what the Office controls.

  12. 2

    Why is the protection of IP rights abroad any concern of the USPTO? It seems to me that the U.S. as a whole, and the USPTO in particular, should be largely indifferent to the internal IP policies of (e.g.) Brazil, or China, or whatnot.

    1. 2.1

      @ Greg

      There is a funny old agreement called TRIPS to which the US is a party.

      If my memory serves, it was instigated by the US prompted by big pharma based in the US. Prior to that there was an insignificant international agreement called the Patents Cooperation Treaty which was also instigated by the US and whose provisions were hammered out by some of the best professionals of the late 1960’s and the 1970’s. PCT Rule 5.1 Manner of the description is a masterpiece that should be re-read periodically by all members of our profession and was the inspiration for the (very successful) technical problem approach of the EPO. There are arguments (contained in a number of amicus briefs that I have written) that the US in its section 101 jurisprudence is in breach of its own treaty.

      For an international portfolio, work sharing, resource sharing and cooperation are to be welcomed. the best searching authority for Japanese patent publications and literature is the Japanese Patent Office, and sharing the results on an exchange basis with the USPTO is common sense and greatly in the interest of applicants.

      A narrow insular approach is not helpful. US exceptionalism should not rule.

      1. 2.1.1

        Thank you, Paul, for that mention of PCT Rule 5(1). I had forgotten its sub-para (v) on “best mode”.

        Drafting is the greatest challenge. We have to see into the technological future, what designs-around will competitors of our client devise. Not only that though. We also have to anticipate what the courts will be thinking, on the issues of law, 20 years from now. You mentuion the “problem” approach of the EPO. Do I not see increasing reference to the “technological problem” in the recently emerging jurisprudence of the CAFC?

        Greg, you ask why the USPTO should be concerned about “IP rights abroad”. Who pays the USPTO for its services? Mostly US nationals. Do any of those US nationals have an interest in “IP rights abroad”? Why would these Americans NOT want the USPTO to take an interest, on their behalf, in “IP rights abroad”?

        1. 2.1.1.1

          MaxDrei,

          I do not think that Greg will find comfort in your answer that the customer’s foreign interests should dictate a sovereign-centric agency’s strategy. Such – on its face – is a reflection of his notion of “capture,” an ill to be avoided.

          Greg is no doubt looking for something more, something outside of any “customer-centric” reasoning.

          Reasons more geared to the Sovereign-centric notion of an agency of the Sovereign.

          In other words, “me me me” from a Sovereign viewpoint and NOT from a (transnational) “customer” viewpoint.

          While he may be too polite to let you know, your answer is likely highly repugnant to him.

        2. 2.1.1.2

          Greg, you ask why the USPTO should be concerned about “IP rights abroad”. Who pays the USPTO for its services? Mostly US nationals.

          As it happens, I believe that you are wrong about most of the USPTO revenue stream coming from U.S. nationals. It was my understanding that applications from ex-U.S. entities outnumber applications from U.S. entities.

          Imagine that you are correct, however. What of it? The USPTO does not exist for the benefit of its ratepayers. It exists for the benefit of U.S. citizens and the economy within the U.S. borders. I am rather uncomfortable with the idea that the USPTO should be overly solicitous of the concerns of those who pay application fees.

      2. 2.1.2

        On the contrary, and in a very real sense, US exceptionalism should be the ONLY thing that rules.

        Patent law was, is, and shall ever be a sovereign-centric domain of law.

        TRIPS just for the sake of TRIPS is an improper “tale of the dog wagging the dog” approach.

        As has been recently discussed, being a signatory to a treaty and enacting any such treaty into national law are two very different things. Our sovereign has set that distinction thoughtfully and carefully and that distinction is a good thing.

        Harmonization for the sake of harmonization simply is not necessarily something that benefits the US sovereign.

        1. 2.1.2.1

          We should harmonize patent law, but to the U.S. standard. Without strong patent protection in other countries, American innovation is appropriated for free when others can read American patents and practice the technology around the world. While a U.S. patent protects innovation in the American market, American companies are disadvantaged by a lack of protection of innovation abroad.
          We no longer live in a world of isolated nations. We have a global economy. For a company to be successful, it needs to be successful globally. To incentivize innovation, global patent protection is needed.
          We should not harmonize to the lowest common denominator, but we should harmonize to a system that promotes and protects innovation.

          1. 2.1.2.1.1

            @ Greenacre

            God forbid that international patent law should be harmonized to the over-elaborate cantankerous unstructured mess of US patent law.

            It does not work satisfactorily at present for Section 101, and I have personally spent some 5 years of comments and briefs trying to move things in a favourable direction.

            The technical problem test is a remarkable tool for evaluating inventive step, was derived from the PCT but its origination was an initiative of the EPO Appeal Board and has been used with great success ever since.

            The reason why it was arrived at was explained in a lecture by George Szabo whose memory I revere. He was a 1956 Hungarian refugee, came to the UK, obtained a technical degree, qualified as a patent attorney and became patents manager for Wellcome. When the EPO started operations he was appointed chairman of one of the technical boards of appeal. Some of the most able European practitioners had been gathered together, but at first had no work to do because first instance decisions had not started to come through. But they did not simply sit on their hands, and instead conducted intensive studies to guide them as to how they should deal with the cases that were likely to come before them. Technical problem emerged during that period as the best test for evaluating inventive step, and since the foundation of the EPO has met with widespread acceptance and a minimal level of public criticism. It is a structured test, unlike the Graham/KSR test which calls for some preliminary investigations but when “make-your-mind-up” time is reached leaves examiners, prosecution attorneys and litigators without any guidance as to the way forward. To be fair, the Windsurfing test of the UK courts suffers from the same defect.

            Post-grant, opposition at the EPO is highly cost-effective and patentees are freely allowed to amend their claims both at first instance and during the appeal stage. Complaints of unfairness have been minimal. Applications to the UK IP Office for revocation are similarly cost-effective, and patentees have broadly similar scope for claim amendment. The UK courts, unfortunately, somewhat mirror their counterparts in the US which is a problem our profession has to live with.

            US companies are not disadvantaged by lack of protection abroad. US inventions can be freely and cost-effectively protected in Europe, by national patents and at the EPO and similar protection is available in China, Japan, Korea and other important manufacturing countries. The benefit to the US of adopting the technical problem test and of reforming the post-grant patent procedure to correspond to that in European oppositions would be overwhelming.

          2. 2.1.2.1.2

            I should mention that my German colleagues have explained to me that the German courts set the standard for infringement proceedings at a cost which is only a small fraction of that in the UK

          3. 2.1.2.1.3

            American companies are disadvantaged by a lack of protection of innovation abroad.

            Two responses:

            (1) What is an “American company”? What does that term mean? Why should most Americans care about such companies (especially given that they quite clearly care so very little about us Americans)?

            (2) How are these (allegedly) “American” companies “disadvantaged by a lack of protection of innovation abroad”? Be specific. Disadvantaged relative to what and whom?

          4. 2.1.2.1.4

            Without strong patent protection in other countries, American innovation is appropriated for free when others can read American patents and practice the technology around the world.

            Is it common for people to learn about technology by reading American patents? If so, do you mean as a primary source by just reading patents as a research tool? Or, do you mean as a secondary source to better understand how an article marked with a patent number works, if necessary?

        2. 2.1.2.2

          @ Anon

          I love the Charming Betsy.

          I leave it to you as a research task (not very difficult) to ascertain who she was, but she was around in 1804, and very beautiful. But it may be that you know of her already.

          1. 2.1.2.2.1

            Charming Betsy canon is a principle of interpretation applied in interpreting national statutes, and general acts of congress. According to this canon, national statutes should be interpreted in such a way that the interpretation does not conflict with international laws. This principle evolved from the case, Murray v. The Schooner Charming Betsy, 6 U.S. 64 (U.S. 1804). In this case the Supreme Court observed that an act of Congress ought never to be construed to violate the law of nations if any other possible construction remains, and consequently can never be construed to violate neutral rights, or to affect neutral commerce.

            The feelings of the Supreme Court – in this regard – are merely feelings. They should not control “just because.”

            Sorry Paul, but I just do not buy into that “One World Order” type of “feelings.” I do not put my Sovereign on “equal footing” with other Sovereigns. I want my Sovereign to be exceptional. As I stated: “in a very real sense, US exceptionalism should be the ONLY thing that rules.”

            You are of course to have a different opinion, and I do not begrudge you your opinion. Just don’t try to force your opinion to be my law.

      3. 2.1.3

        Dear Paul,

        Thank you for your typically thoughtful and engaging response. I have a few thoughts to offer in return:

        (1) For an international portfolio, work sharing, resource sharing and cooperation are to be welcomed… A narrow insular approach is not helpful. US exceptionalism should not rule.

        I agree entirely. My apologies if my earlier post was unclear, but I certainly did not mean to imply that I would prefer the US to take a “US exceptionalism” stance. To the extent that the PTO means merely that it wishes to see international agreements implemented in a manner that accentuates international harmonization, I am all in favor.

        It seems strange, however, to my ear to call that sort of effort “[p]rotecting IP rights abroad” (emphasis added). When I read the word “protecting,” I think of the PTO bullet point “[w]ork with the administration to improve IP enforcement… in countries of interest.” I do not know why the U.S. (or the USPTO), qua United states, should much care about enforcement of IP in (e.g.) Mexico. IP is a matter for each sovereign to manage for its own benefits. If Mexico prefers to place less emphasis on making Mexican IP enforceable than the U.S. places on making U.S. IP enforceable, that is a very legitimate policy stance for Mexico to take, and none of our business.

        2) [A] funny old agreement called TRIPS[,] to which the US is a party…[,] was instigated by the US prompted by big pharma based in the US.

        Er, yes, it was. I happen to like TRIPS, but I am not wild about the political economy that gives rise to agreements like TRIPS. As it happens, I think that TRIPS was in our national interest, so it is fine that the U.S. should sign on to such a treaty. I am uneasy, however, with the idea of the U.S. acting to pressure other nations—whose interests may or may not be advanced by a given IP treaty—to sign such treaties. I am especially uneasy about this when the U.S. does so at the behest of a handful of corporations—some of which are headquartered in our borders, many of which are not, and all of which would cheerfully sell the U.S. down the river for a bag of beans if they thought it would improve their quarterly earnings statements by even $1.50.

        Corporate capture of the powers of government, and the corresponding rent-seeking that go with such capture, are a poison on our society. It is distressing to see the PTO cheerfully acknowledging such capture and rent-seeking as one of its performance goals.

        1. 2.1.3.1

          [A] handful of corporations…[,] all of which would cheerfully sell the U.S. down the river for a bag of beans if they thought it would improve their quarterly earnings statements by even $1.50.

          Just to be clear, I do not mean to direct special invective at the pharma industry when I write this. I love the pharma industry. I think that the pharma industry is—broadly speaking—a force for good in the world. I am in-house counsel to a pharma company, and I am proud of the work my company does.

          I think that all corporations, however, have an unwholesome temptation to try to direct the mechanisms of government to their own private ends. This is just as true of (e.g.) tech, or agriculture, or manufacturing (etc) as it is of pharma. It is natural enough that corporations should try to achieve such rent-seeking government benefits, but government should not accede to these efforts. Our government should set policy with regard to the good of U.S. citizens, not corporations (even when such corporations style themselves as “American companies,” whatever that term means).

          1. 2.1.3.1.1

            Interestingly enough, we have both alignment and misalignment on this topic.

            Both on “US first”

  13. 1

    #1: Issuing reliable IP rights

    Hallelujah.

    Director Lee had three and a half years to address this issue. She failed to do so because, as best I can tell, she did not even recognize it as a problem. I suspect that her agenda was set by her experiences as Google Deputy GC and was embodied by Alice, which sent us to the awful inconsistency problem that we have today.

    I couldn’t be more encouraged by Director Iancu’s broad perspective and the specific initiatives outlined in this draft. Colleagues, this is a new day.

    1. 1.1

      Naturally, I agree entirely with listing “reliable IP rights” as goal #1. If this were a patent, I would worry about enablement (how is this directorate going to achieve that goal when so many before have not?), but this is certainly the right goal for the USPTO to have. Knowing your destination is not—by itself—sufficient to arrive at the destination, but it is a necessary precondition, so this goal is at least a good start.

    2. 1.2

      The term “reliable patents” is not synonymous with “quality patents,” David. It’s code for the idea that we’re going to make patents harder to challenge, perhaps by diluting avenues for post-grant review, regardless of the quality. There’s tons of doublespeak in these bullet points, here pushing the emphasis toward “consistent outcomes” and “reliability,” rather than quality (which is barely mentioned).

      Reliability is only a good goal when the patents are good; junk patents that are “reliable” is a scourge.

      Iancu is a true Trump-era agency official. Perhaps he’s realized that with PTO policies that incentivize examiner productivity, mediocrity and apathy over quality, improving the quality of examination is simply never going to happen in an ex parte examination regime. So I suppose, he is thinking, why bother repeating the same promise of improved quality that Dudas/Kappos/Lee repeatedly espoused but on which they could never deliver.

      1. 1.2.2

        The term “reliable patents” is not synonymous with “quality patents,” David. It’s code for the idea that we’re going to make patents harder to challenge, perhaps by diluting avenues for post-grant review, regardless of the quality.

        How do you figure? Look at the bullets in the “reliability” box above (e.g., “[i]ncrease examiners’ ability to obtain the best prior art,” or “[e]mphasize… reasoning of orders and opinions, and decisional consistency”). Maybe the Director is just lying when he writes these goals, but there is nothing here that really suggests a desire to “dilut[e] avenues for post-grant review…”

      2. 1.2.3

        “The term “reliable patents” is not synonymous with “quality patents,” David. It’s code for the idea that we’re going to make patents harder to challenge”

        That’s an interesting theory. All the bullet-points under “reliable patents” appear to be directed to the examination process rather than anything else. What makes you think this a dog-whistle, rather than merely a desire to repeat the “quality” mantra in a different voice?

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