The USPTO recently asked for public comments regarding proposed changes to renewal filings, namely a program whereby 10% of submissions may be required to submit additional evidence of use beyond the current requirement of one specimen per International Class of goods and/or services.

Our firm submitting the following comments:

Others, including major IP associations, submitted comments as well. Many of the comments supported the program, many expressed concerns about how it will be implemented.

The full text of all the comments submitted to the USPTO can be found here:


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