AIPLA Comments on DOCX Submission Requirements
Written October 31, 2023
Arlington, VA. October 27, 2023 - The American Intellectual Property Law Association (AIPLA) submitted comments in response to a series of Federal Register Notices of Information Collection (NOIC) inviting comments on proposed information collection concerning DOCX Submission Requirements.
The comments express concern about the use of the DOCX format for patent applications, emphasizing that it is not globally standardized and would impose a greater financial burden on the public. They also questioned the efficacy of DOCX in meeting disclosure requirements. Despite their reservations, the Office has decided to continue with DOCX standards and impose fees for non-compliance. The comments propose allowing applicant-generated PDFs alongside DOCX. While some internal processes may allow corrections based on PDFs, AIPLA is concerned about the legal sufficiency of such corrections and their acceptance internationally. They highlighted that other organizations permit both pre-conversion DOCX and PDFs, which can be recognized as official views and corrected if needed. Additionally, they raised concerns that the Office's stance would disproportionately affect small and medium entities and independent patent applicants, hindering their participation in the patent system. AIPLA expressed their willingness to continue collaborating with the Office.
To view the complete comments, please download the comment letter posted to the right of this page.