Justification for Change to 0651-0035

JUSTIFICATION FOR NONMATERIAL/NONSUBSTANTIVE CHANGE TO 0651-0035
The United States Patent and Trademark Office (USPTO) is submitting this change worksheet
to add forms for associating USPTO Customer Numbers with international Patent Cooperation
Treaty (PCT) applications into information collection 0651-0035 Representative and Address
Provisions, which was previously approved by OMB on 12/27/2005. The currently approved
collection includes forms that allow customers to associate their Customer Numbers with their
U.S. patent applications, which is a requirement for customers who wish to access private
information about their applications using the Patent Application Information Retrieval (PAIR)
system on the USPTO web site. The PAIR system permits authorized individuals secure
access to application status information over the Internet, but only for applications that are
linked to a Customer Number. The USPTO is extending this practice to allow customers to
associate Customer Numbers with international PCT applications as well as U.S. patent
applications. In order to support this practice, the USPTO is developing a form to allow
customers to associate a Customer Number with a single PCT application and a sample
spreadsheet to allow customers to associate a Customer Number with multiple PCT
applications at once. The USPTO requests that the proposed Form PTO-2248 Request to
Update a PCT Application with a Customer Number and the Customer Number Upload
Spreadsheet for PCT Applications be added to this collection.
Change in Burden
The USPTO estimates that it will receive approximately 22,500 responses per year for the
proposed Form PTO-2248 for the two years remaining in the renewal period for this collection
and that it will take the public approximately 15 minutes (0.25 hours) to prepare and submit the
form, for an addition of 5,625 burden hours to this collection. The USPTO estimates that it will
receive approximately 2,000 responses per year for the proposed Customer Number Upload
Spreadsheet for PCT Applications and that it will take the public approximately 1 hour to
prepare and submit the spreadsheet, depending upon how many applications are listed, for an
addition of 2,000 burden hours to this collection. Therefore, the addition of these items will
result in an increase of 24,500 annual responses and 7,625 burden hours for this collection as a
program change.
The addition of these items will also increase the annual (non-hour) costs for this collection.
Customers may incur postage costs for submitting the form or spreadsheet to the USPTO by
mail. At this time, neither item may be submitted to the USPTO electronically. The USPTO
estimates that the average first-class postage cost will be 39 cents for submitting Form PTO2248 and 87 cents for submitting the PCT Customer Number Upload Spreadsheet, for a total
addition of $10,515 in postage costs for this collection. Customers may also incur capital startup costs associated with the PCT Customer Number Upload Spreadsheet, which must be
submitted to the USPTO on a CD or diskette along with a signed cover letter. This process
requires additional supplies, including blank media and padded envelopes for shipping. The
USPTO estimates that the cost of these supplies will be approximately $2 per submission, for a
total addition of $4,000 in capital start-up costs for this collection. Therefore, the addition of
these items will result in an increase of $14,515 in annual (non-hour) costs for this collection as
a program change.
Copies of the proposed Form PTO-2248 Request to Update a PCT Application with a Customer
Number and the proposed Customer Number Upload Spreadsheet for PCT Applications have
been attached to this submission.