NIPRA wishes to thank Chairman Coble and Ranking Member Berman for their April 9th, 2001 letter to Director Godici expressing concerns with the possible premature disposition of the paper files and the public library collections. We believe the indefinite preservation of these facilities is of critical importance to the quality of issued patents and registered trademarks.

NIPRA proposes the consolidation of existing public search facilities into an expanded Single Central Search Facility (SCSF) to be housed in the Crystal City complex; the expansion to include integration of all foreign patents and digests that may be removed from the examiners' search areas.

The need to maintain and expand the publicly available hard copy search files will be presentforatleastthenext8-10years. NIPRAproposesathreeyearside-by-side comparison of newly issued patents before building down the examiners' hard copy files, followed by a five year incrementally phased building down of the public's hard copy files as the most responsible way to handle the risks associated with these historic steps.

It has been asserted by many that the proper classification of patents and other references is no longer necessary because "we now have word searching." NIPRA disagrees. We believe the recent downgrading of the PTO's classification efforts is having a negative impact on patent and trademark quality, and the benefits of the hard copy files will soon disappear without resuming serious classification efforts.

The matter of relocating or restructuring the PTO's former Office of Quality Review should be the subject of intense review by all in the IP community. NIPRA suggests the necessity of separating tl@s crucial function from the Technology Centers where it is now based and reconstituting it in a newly formed organization.

The issue of improving quality and curing defects of U.S. patents has a virtually exact analog with respect to registering U.S. trademarks. For the same reasons as in patent matters, the hard copy trademark paper search facilities must be preserved for the foreseeable future.

Jim Cottone, Hon. Howard Coble, Joe Clawson, Randy Rabin, Bob Weir