Agency Information Collection Activities; Proposals, Submissions, and Approvals: DOCX Submission Requirements

Richard Neifeld of Neifeld IP Law, PLLC, opposes the USPTO's DOCX submission requirements, arguing that the "DOCX" format is not a single standard and that the USPTO's conversion algorithm is unreliable and burdensome. He contends that the process forces users to perform manual reviews to ensure data integrity, creating unnecessary costs and liability for patent practitioners.

Brian Schar, a registered patent attorney at CrossPond Law, argues that the USPTO's estimated time burden for DOCX filings is significantly underestimated. He contends that technical issues with DOCX files, such as incorrect feedback documents, font errors, and equation formatting, make the process much more time-consuming than the proposed 30 minutes.

Neil R. Ormos argues that the USPTO has significantly underestimated the time burden of filing patent applications in DOCX format. He provides detailed estimates showing that complex applications with special characters or those received from third parties can require several hours of additional work due to the PTO's arbitrary stylistic preferences and rendering inconsistencies.

A registered patent attorney at a small IP firm opposes the DOCX submission requirements, arguing that they impose an unequal burden on small applicants and foreign associates who may not use Microsoft Word. The commenter also criticizes the high DOCX surcharge and suggests that the USPTO should allow PDF submissions without a fee.

A registered patent attorney at a small IP firm opposes the DOCX submission requirements, arguing that the software costs and technical troubleshooting burdens are disproportionately high for small applicants and foreign associates. They also contend that the DOCX surcharge is unreasonably high compared to the actual cost of processing and suggest that the USPTO should allow PDF submissions without a surcharge.

David Boundy, a patent practitioner, opposes the USPTO's proposed DOCX submission requirements, arguing that the DOCX format is unreliable for consistent rendering and that the agency's burden estimates are significantly underestimated. He advocates for allowing users to file in their preferred reliable format (such as PDF/A) without a surcharge, citing technical standards and the lack of objective support for the USPTO's claims.

David Boundy, representing PTAAARMIGAN (along with representatives from AIPLA and NAPP), opposes the USPTO's move to adopt DOCX as a filing standard. He argues that DOCX is unreliable for patent filings compared to the PDF/A standard, citing technical flaws, potential for data corruption, and a lack of adherence to voluntary consensus standards.

David Boundy, representing PTAAARMIGAN (along with AIPLA and NAPP), opposes the USPTO's transition to DOCX filing requirements. He argues that DOCX is an unreliable, non-standard format that introduces significant errors in patent applications compared to the voluntary consensus standard, PDF/A.

Daniel Feigelson, a patent practitioner, opposes the USPTO's DOCX submission requirements, arguing that the "estimated burden" is significantly underestimated. He contends that DOCX is a proprietary format that can lead to display errors and that the PTO should instead allow PDF/A submissions, which are standard in other international patent offices.