AIPLA Submits Comments on Proposed Administrative Updates to the General Requirements Bulletin

Written May 24, 2021

On May 24, 2021, AIPLA submitted comments to the Director for the Office of Enrollment and Discipline at the U.S. Patent and Trademark Office (USPTO) regarding the proposed administrative updates to the General Requirements Bulletin (GRB). AIPLA believes that regular updates to the GRB are necessary to keep pace with evolving technology and corresponding patentable innovations. Updating the GRB on an ongoing basis will help create a dynamic workforce to represent applicants before the Office for all technical fields.

First and foremost, the integrity of the patent system should be the paramount goal. Changes to the GRB should contribute toward ensuring a robust well-functioning patent system. AIPLA also believes that streamlining the application process for certain applicants and helping bring more qualified practitioners into the patent system will benefit both the Office and stakeholders in the United States patent system. The qualifications should reflect the entire spectrum of patenting activity without arbitrary, overly restrictive, or excessively burdensome or biased requirements.

Specifically, AIPLA agrees with the proposal to add the common Category B categories to Category A to reflect current and anticipated patenting activity and advise considering the addition of degrees matching emerging technical fields on a regular basis. Additionally, AIPLA supports the inclusion of master’s and doctoral degrees as acceptable under the requirements of Category A. Finally, AIPLA agrees with the USPTO’s proposal to amend Category B, Options 2 and 4, to permit a combination of courses that need not be sequential.

AIPLA recommends a formal review of the degrees being offered, which of course, include those offered by historically diverse institutions. AIPLA is not aware of any persuasive reason that advanced degrees should be excluded as providing evidence of sufficient technical knowledge to qualify under 37 CFR §11.7(b). Thus, AIPLA is in support of the inclusion of masters and doctoral degrees as acceptable under the requirements of Category A.

To read the full comments, please download the file.