0651-0056 Final SupStmt June 2011

SUPPORTING STATEMENT
United States Patent and Trademark Office
Submissions Regarding Correspondence and Regarding
Attorney Representation (Trademarks)
OMB Control Number 0651-0056
(June 2011)

A.

JUSTIFICATION

1.

Necessity of Information Collection

The United States Patent and Trademark Office (USPTO) administers the Trademark
Act, 15 U.S.C. § 1051 et seq., which provides for the Federal registration of trademarks,
service marks, collective trademarks and service marks, collective membership marks,
and certification marks. Individuals and businesses that use, or intend to use, such
marks in commerce may file an application to register their marks with the USPTO.
Such individuals and businesses may also submit various communications to the
USPTO regarding their pending applications or registered trademarks, including
providing additional information needed to process a pending application, filing
amendments to the applications, or filing the papers necessary to keep a trademark in
force. In the majority of circumstances, individuals and businesses retain attorneys to
handle these matters. As such, these parties may also submit communications to the
USPTO regarding the various activities related to the appointment and retention of
attorneys and domestic representatives. Applicants and registrants may also submit
change of address forms requesting that the USPTO amend the record of an application
or registration by entering the new address.
The rules implementing the Trademark Act are set forth in 37 CFR Part 2. In addition to
governing the registration of trademarks, the Act and rules also govern the
appointments and revocations of attorneys and domestic representatives.
The
trademark rules provide the specifics for filing requests for permission to withdraw as
the attorney of record. The requirements for changes of the owner’s address are not
governed by the trademark rules, but are outlined in the USPTO’s procedures.
The information in this collection can be submitted in paper format or electronically
through the Trademark Electronic Application System (TEAS). The USPTO has
developed a new TEAS Global Form format that permits the agency to collect
information electronically when a TEAS form having dedicated data fields is not yet
available. This collection currently has three TEAS forms with dedicated data fields. As
part of this renewal, the USPTO proposes to add three TEAS Global Forms – for
changing the domestic representative’s address, replacing the attorney of record with
another already appointed attorney, and requesting the withdrawal of a domestic

representative – into the collection. The paper equivalents will be added as well. There
are no official paper forms available for these items.
Table 1 identifies the statutes and rules that permit the USPTO to collect the information
needed to process these submissions.
Table 1: Information Requirements for Submissions Regarding Correspondence and Regarding
Attorney Representation (Trademarks)
Requirement

Statute

Rule

15 U.S.C. §§ 1051(e),
1058(f), 1123, and 1141h(d)

37 CFR Part 2, 2.17, 2.19, 2.24,
and 2.193

Request for Permission to Withdraw as Attorney of Record

15 U.S.C. § 1123

37 CFR Part 2, 2.19

Change of Owner’s Address Form

15 U.S.C. § 1123

37 CFR Part 2, 2.18 and 2.193

15 U.S.C. §§ 1051(e),
1058(f), 1123, and 1141h(d)

37 CFR Part 2, 2.18, 2.24, and
2.193

15 U.S.C. § 1123

37 CFR Part 2, 2.17

15 U.S.C. §§ 1051(e),
1058(f), 1123, and 1141h(d)

37 CFR Part 2, 2.17 and 2.24

Revocation of Attorney/Domestic Representative and/or
Appointment of Attorney/Domestic Representative

Change of Domestic Representative’s Address

Replacement of Attorney of Record with Another Already
Appointed Attorney
Request to Withdraw as Domestic Representative

2.

Needs and Uses

The USPTO uses the information described in this collection in various actions
concerning the appointment and retention of attorneys and domestic representatives.
The information in this collection is a matter of public record and is used by the public
for a variety of private business purposes related to establishing and enforcing
trademark rights. The information is available at USPTO facilities and can also be
accessed at the USPTO web site. Additionally, the USPTO provides the information to
other entities, including Patent and Trademark Depository Libraries (PTDLs). The
PTDLs maintain the information for use by the public.
With the introduction in this renewal of the TEAS Global Forms format, the information
in this collection can be collected in three different formats: paper format, electronically
using the original TEAS forms, or electronically using the new TEAS Global Forms.
This collection currently has three original TEAS forms with dedicated data fields;
however, there are no official paper forms for these items. Individuals and businesses
can submit their own paper forms, following the USPTO’s rules and guidelines to ensure
that all of the necessary information is provided. Applicants who choose to submit their
applications electronically must use the TEAS forms.
The Information Quality Guidelines from Section 515 of Public Law 106-554, Treasury
and General Government Appropriations Act for Fiscal Year 2001, apply to this
information collection and this information collection and its supporting statement
comply with all applicable information quality guidelines, i.e., OMB and specific
operating unit guidelines.

2

This proposed collection of information will result in information that will be collected,
maintained, and used in a way consistent with all applicable OMB and USPTO
Information Quality Guidelines.
(See Ref. A, the USPTO Information Quality
Guidelines.)
Table 2 lists the information identified in this collection and explains how this information
is used by the public and by the USPTO:
Table 2: Needs and Uses of Information Collected for Submissions Regarding Correspondence
and Regarding Attorney Representation (Trademarks)
Form and Function

Form #

Revocation of Attorney/Domestic
Representative and/or
Appointment of Attorney/Domestic
Representative (Paper)

No Form
Associated

Needs and Uses
•
•
•

TEAS Revocation of
Attorney/Domestic Representative
and/or Appointment of
Attorney/Domestic Representative
(Ref. B)

PTO Form 2196

•

•
•

Request for Permission to
Withdraw as Attorney of Record
(Paper)

No Form
Associated

TEAS Request for Permission to
Withdraw as Attorney of Record
(Ref. C)

PTO Form 2201

Change of Owner’s Address Form
(Paper)

•
•
•
•

No Form
Associated

•
•

TEAS Change of Owner’s Address
(Ref. D)

PTO Form 2197

•
•

Change of Domestic
Representative’s Address (Paper)

No Form
Associated

•
•

Used by applicants and registrants to appoint an attorney to act on
their behalf in connection with single or multiple applications or
registrations and to revoke such appointments.
Used by foreign applicants and registrants to designate a domestic
representative upon whom to serve notices or process in legal
proceedings affecting the mark.
Used by the USPTO to process requests to appoint
attorneys/domestic representatives and to process requests to
revoke such appointments.
Used by applicants and registrants to electronically transmit
appointments of attorneys to act on their behalf in connection with
single or multiple applications or registrations and to electronically
transmit revocations of those appointments.
Used by foreign applicants and registrants to electronically designate
a domestic representative upon whom to serve notices or process in
legal proceedings affecting the mark.
Used by the USPTO to process electronically filed requests to
appoint attorneys/domestic representatives, and to process
electronically filed requests to revoke such appointments.
Used by attorneys to submit a request for permission to withdraw as
the attorney of record.
Used by the USPTO to process requests for permission to withdraw
as the attorney of record.
Used by attorneys to electronically submit a request for permission to
withdraw as the attorney of record.
Used by the USPTO to process electronically filed requests for
permission to withdraw as the attorney of record.
Used by applicants and registrants to submit a request that the
USPTO amend the record of an application or registration by entering
a new address for the applicant or registrant.
Used by the USPTO to process requests to change the address of
the applicant or registrant that is identified in the application or
registration.
Used by applicants and registrants to electronically submit a request
that the USPTO amend the record of an application or registration by
entering a new address for the applicant or registrant.
Used by the USPTO to process electronically filed requests to
change the address of the applicant or registrant that is identified in
the application or registration.
Used by applicants and registrants to submit a request that the
USPTO amend the record of an application or registration by entering
a new address for the domestic representative.
Used by the USPTO to process requests to change the address of a
domestic representative.

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Form and Function
Change of Domestic
Representative’s Address (TEAS
Global) (Ref. E)

Form #
TEAS Global
Form

Needs and Uses
•
•

Replacement of Attorney of
Record with Another Already
Appointed Attorney (Paper)

No Form
Associated

•

•

Replacement of Attorney of
Record with Another Already
Appointed Attorney (TEAS Global)
(Ref. F)

TEAS Global
Form

•

•

Request to Withdraw as Domestic
Representative (Paper)

No Form
Associated

•
•

Request to Withdraw as Domestic
Representative (TEAS Global)
(Ref. G)

3.

TEAS Global
Form

•
•

Used by applicants and registrants to electronically submit a request
that the USPTO amend the record of an application or registration by
entering a new address for the domestic representative.
Used by the USPTO to process electronically filed requests to
change the address of a domestic representative.
Used by applicants and registrants to submit a request that the
USPTO amend the record of an application or registration by
replacing the named attorney of record with another previously
appointed associate attorney.
Used by the USPTO to process requests that the named attorney of
record be replaced with another previously appointed associate
attorney.
Used by applicants and registrants to electronically submit a request
that the USPTO amend the record of an application or registration by
replacing the named attorney of record with another previously
appointed associate attorney.
Used by the USPTO to process electronically filed requests that the
named attorney of record be replaced with another previously
appointed associate attorney.
Used by domestic representatives to submit a request to withdraw as
the domestic representative.
Used by the USPTO to process requests by domestic
representatives to withdraw.
Used by domestic representatives to electronically submit a request
to withdraw as the domestic representative.
Used by the USPTO to process electronically filed requests by
domestic representatives to withdraw.

Use of Information Technology

The USPTO currently offers four IT systems in support of this collection that are
accessible through the online Trademark Electronic Business Center (TEBC). The
TEBC provides descriptions of the systems, and the systems feature online “help”
programs. Thus, the USPTO offers the public a single source for a variety of IT
systems useful both for making submissions to the USPTO and for tracking the status of
these submissions.
The USPTO provides online electronic forms, with dedicated data fields, through the
web-accessible Trademark Electronic Application System (TEAS) for appointing an
attorney or domestic representative, for revoking those appointments, to request
permission to withdraw as the attorney of record, and to change the owner’s address.
In addition, the USPTO has developed a new TEAS Global Form format that allows the
agency to collect information electronically when a TEAS form having dedicated data
fields is not yet available. At this time, three new TEAS Global Forms are being added
into this collection.
Once completed, TEAS forms are transmitted to the USPTO via the Internet. The
TEAS forms include “help” instructions, as well as a “Form Wizard” that tailors the form
to the particular characteristics of the application or registration in question, based on
responses provided by the user to questions posed by the Form Wizard. The forms

4

filed are received within seconds after transmission, and a confirmation of filing is
immediately e-mailed to the user.
Users do not affix digital signatures to the TEAS forms. Instead, these forms are signed
using a combination of alphanumeric characters that the user selects and types
between two forward slashes. TEAS forms can be signed in this manner, or the text
form of the application can be e-mailed to a second party who can then electronically
sign the application. The forms can also be signed by printing the signature page of the
form, signing it in ink, scanning the signed page, and then transmitting the entire form
and scanned signature page to the USPTO.
Please note that electronic forms can only be submitted via TEAS; filers may not e-mail
their own forms to the USPTO. Additionally, filers who submit drawings of marks that
are not “standard character” drawings must attach digitized images of these drawings to
their submissions.
The USPTO maintains an online image database of the electronic trademark application
or registration file wrappers, entitled the Trademark Document Retrieval (TDR) system,
from which the public can view and print images of the contents of trademark
application and registration records. The USPTO also maintains an online system
called the Trademark Application and Registration Retrieval (TARR) system, which
provides users with information regarding the status of trademark applications and
registrations. The data in the TARR system is updated daily.
The USPTO provides a web-based record of registered marks, and marks for which
applications for registration have been submitted, called the Trademark Electronic
Search System (TESS). TESS can be used by potential applicants for trademark
registration to assist in the determination of whether or not a particular mark may be
available. The data in TESS is identical to the data reviewed by examining attorneys at
the USPTO in their determination of whether marks for which registration is sought are
confusingly similar to marks in existing registrations or to marks in pending applications
for registration. TESS allows the user to choose from four different search tools, is
updated daily, and is easy to use.
4.

Efforts to Identify Duplication

This information is collected only when appointments of attorneys/domestic
representatives, revocations of attorneys/domestic representatives, requests for
permission to withdraw as the attorney of record, change of owner’s and domestic
representative’s addresses, replacements of attorney of record with another already
appointed attorney, and requests to withdraw as a domestic representative are
submitted to the USPTO. This collection does not solicit any data that is already
available at the USPTO, nor does it create a duplication of effort.

5

5.

Minimizing the Burden to Small Entities

The USPTO believes that the submission of this information places no undue burden on
small businesses or other small entities. The same information is required from every
customer and is not available from any other source.
6.

Consequences of Less Frequent Collection

This information collection could not be conducted less frequently, since the information
is collected only when voluntarily submitted by the public. If the information were not
collected, applicants and registrants could not appoint attorneys/domestic
representatives to represent them at the USPTO or revoke those appointments, nor
could they request address changes. Likewise, attorneys and domestic representatives
could not request permission to withdraw as the attorney of record or the domestic
representative, nor could applicants and registrants request replacement of the attorney
of record with another already appointed attorney. If this information was not collected,
the USPTO could not comply with the requirements of the Trademark Act, 15 U.S.C. §
1051 and 37 CFR Part 2.
7.

Special Circumstances in the Conduct of Information Collection

There are no special circumstances associated with this collection of information.
8.

Consultation Outside the Agency

The 60-Day Federal Register Notice was published on March 15, 2011 (76 Fed Reg.
13987). The public comment period ended on May 16, 2011. No public comments
were received in response to the Notice.
Large and well-organized bar associations frequently communicate their views to the
USPTO. Also, the Trademark Public Advisory Committee (T-PAC) was created by the
American Inventors Protection Act of 1999 to advise the Director of the USPTO on the
agency’s operations, including its goals, performance, budget, and user fees. The TPAC includes nine voting members who are appointed by and serve at the pleasure of
the Secretary of Commerce. The statute also provides non-voting membership on the
Committee for the agency’s three recognized unions. Members include inventors,
lawyers, corporate executives, entrepreneurs, and academicians with significant
experience in management, finance, science, technology, labor relations, and
intellectual property issues. The members of T-PAC reflect the broad array of USPTO’s
stakeholders and embrace the USPTO’s e-government initiative. This diversity of
interests is an effective tool in helping the USPTO nurture and protect the intellectual
property that is the underpinning of America’s strong economy.
9.

Payment or Gifts to Respondents

This information collection does not involve a payment or gift to any respondent.

6

10.

Assurance of Confidentiality

Trademark applications and registrations are open to public inspection. Confidentiality
is not required in the processing of trademark applications.
Apart from the substantive components and burden statements, the TEAS forms also
include a link to the USPTO’s Web Privacy Policy. The “Privacy Policy Statement” link
is located above the PRA Burden Statement found at the end of the Form Wizard and at
the end of the forms themselves. The Web Privacy Policy Statement explains how the
USPTO handles any personal information collected from the public through the web site
and how it handles e-mails. Additionally, the statement also explains what information
is collected through the USPTO’s Kid Pages and whether and why the USPTO uses
cookies to collect information.
11.

Justification for Sensitive Questions

None of the required information in this collection is considered to be of a sensitive
nature.
12.

Estimate of Hour and Cost Burden to Respondents

Table 3 calculates the anticipated burden hours and costs of this information collection
to the public, based on the following factors:
•

Respondent Calculation Factors
The USPTO estimates that it will receive approximately 123,010 responses per year for
this collection, with 117,151 of them filed electronically.

•

Burden Hour Calculation Factors
The USPTO estimates that it takes the public approximately 5 to 30 minutes (0.08 to
0.50 hours) to complete this information, depending upon the amount and type of
information requested in a particular case. This includes the time to gather the
necessary information, prepare the requests, and submit them to the USPTO. The time
estimates shown for the electronic forms in this collection are based on the average
amount of time needed to complete and electronically file the associated form.

•

Cost Burden Calculation Factors
The USPTO expects that attorneys will complete these submissions. The professional
hourly rate of $325 used in this submission to calculate the respondent cost burden is
the median rate for attorneys in private firms as published in the 2009 report of the
Committee on Economics of Legal Practice of the American Intellectual Property Law
Association (AIPLA). This report summarized the results of a survey with data on hourly
billing rates. This is a fully-loaded rate.

7

Table 3: Burden Hour/Burden Cost to Respondents
Item

Hours
(a)

Responses
(yr)
(b)

Burden
(hrs/yr)
(c)
(a) x (b)

Rate
($/hr)
(d)

Total Cost
($/hr)
(e)
(c) x (d)

Revocation of Attorney/Domestic Representative
and/or Appointment of Attorney/Domestic
Representative (Paper)

0.17

4,000

680

$325.00

$221,000.00

TEAS Revocation of Attorney/Domestic
Representative and/or Appointment of
Attorney/Domestic Representative (PTO Form 2196)

0.08

80,000

6,400

$325.00

$2,080,000.00

Request for Permission to Withdraw as Attorney of
Record (Paper)

0.25

225

56

$325.00

$18,200.00

TEAS Request for Permission to Withdraw as
Attorney of Record (PTO Form 2201)

0.20

4,500

900

$325.00

$292,500.00

Change of Owner’s Address (Paper)

0.17

1,600

272

$325.00

$88,400.00

TEAS Change of Owner’s Address Form
(PTO Form 2197)

0.08

32,000

2,560

$325.00

$832,000.00

Change of Domestic Representative’s Address
(Paper)

0.17

13

2

$325.00

$650.00

Change of Domestic Representative’s Address
(TEAS Global)

0.08

250

20

$325.00

$6,500.00

Replacement of Attorney of Record with Another
Already Appointed Attorney (Paper)

0.50

1

1

$325.00

$325.00

Replacement of Attorney of Record with Another
Already Appointed Attorney (TEAS Global)

0.50

1

1

$325.00

$325.00

Request to Withdraw as Domestic Representative
(Paper)

0.17

20

3

$325.00

$975.00

Request to Withdraw as Domestic Representative
(TEAS Global)

0.08

400

32

$325.00

$10,400.00

Total

- - - -

123,010

10,927

- - - -

$3,551,275.00

13.

Total Annualized Cost Burden

This information collection has postage costs associated with it. It does not have any
operation or maintenance costs, nor does it have filing fees.
Customers incur postage costs when submitting the information in paper format to the
USPTO by mail through the United States Postal Service. The USPTO estimates that
the majority (98%) of the paper forms are submitted to the USPTO via first-class mail.
The USPTO estimates that these submissions will typically weigh approximately one
ounce and that the first-class postage rate for these submissions is 44 cents. Out of
5,859 paper submissions, the USPTO estimates that 5,741 will be mailed to the agency.
Therefore, the USPTO estimates that the total postage cost for this collection is $2,526
per year.

8

Table 4 calculates the postage costs for submissions regarding correspondence and
regarding attorney representation (Trademarks).
Table 4: Postage Costs for Submissions Regarding Correspondence and Regarding Attorney
Representation (Trademarks)
Item

Responses
(yr)
(a)

Revocation of Attorney/Domestic Representative and/or Appointment of
Attorney/Domestic Representative
Request for Permission to Withdraw as Attorney of Record
Change of Owner’s Address Form
Change of Domestic Representative’s Address
Replacement of Attorney of Record with Another Already Appointed Attorney
Request to Withdraw as Domestic Representative
Total

Postage
Costs
(b)

Total Cost
(yr)
(a) x (b)

3,920

$0.44

$1,725.00

221

$0.44

$97.00

1,568

$0.44

$690.00

12

$0.44

$5.00

1

$0.44

$1.00

19

$0.44

$8.00

5,741

- - - - -

$2,526.00

The USPTO estimates that the total annualized (non-hour) cost burden for this
collection is $2,526 per year.
14.

Annual Cost to the Federal Government

The USPTO estimates that it takes a GS-7, step 5 employee between 5 and 7 minutes
(0.08 and 0.12 hours) to process the revocations and appointments, between 1 and 5
minutes (0.02 and 0.08 hours) to process the change of owner’s address, and between
3 and 5 minutes (0.05 and 0.08 hours) to process the change of domestic
representative’s address, replacement of attorney of record with another already
appointed attorney, and request to withdraw as domestic representative. The current
hourly rate for a GS-7, step 5 is $22.92. When 30% is added to account for a fully
loaded hourly rate (benefits and overhead), the cost per hour for a GS-7, step 5 is
$22.92 + $6.88, for a rate of $29.80.
The USPTO estimates that it takes a GS-15, step 5 employee 10 minutes (0.017 hours)
to process the requests for permission to withdraw as the attorney of record filed on
paper, but only 1 minute (0.02 hours) to process those that are filed through TEAS. The
current hourly rate for a GS-15, step 5 is $67.21. When 30% is added to account for a
fully loaded hourly rate (benefits and overhead), the combined cost per hour for a GS15, step 5 is $67.21 + $20.16, for a rate of $87.37.
Table 6 calculates the processing hours and costs of this information collection to the
Federal Government:

9

Table 6: Burden Hour/Burden Cost to the Federal Government
Item

Hours
(a)

Responses
(yr)
(b)

Burden
(hrs/yr)
(c)
(a) x (b)

Rate
($/hr)
(d)

Total Cost
($/hr)
(e)
(c) x (d)

Revocation of Attorney/Domestic Representative
and/or Appointment of Attorney/Domestic
Representative (Paper)

0.12

4,000

480

$29.80

$14,304.00

TEAS Revocation of Attorney/Domestic Representative
and/or Appointment of Attorney/Domestic
Representative (PTO Form 2196)

0.08

80,000

6,400

$29.80

$190,720.00

Request for Permission to Withdraw as Attorney of
Record (Paper)

0.17

225

38

$87.37

$3,320.00

TEAS Request for Permission to Withdraw as Attorney
of Record (PTO Form 2201)

0.02

4,500

90

$87.37

$7,863.00

Change of Owner’s Address (Paper)

0.08

1,600

128

$29.80

$3,814.00

TEAS Change of Owner’s Address Form
(PTO Form 2197)

0.02

32,000

640

$29.80

$19,072.00

Change of Domestic Representative’s Address (Paper)

0.08

13

1

$29.80

$30.00

Change of Domestic Representative’s Address
(TEAS Global)

0.05

250

13

$29.80

$387.00

Replacement of Attorney of Record with Another
Already Appointed Attorney (Paper)

0.08

1

1

$29.80

$30.00

Replacement of Attorney of Record with Another
Already Appointed Attorney (TEAS Global)

0.05

1

1

$29.80

$30.00

Request to Withdraw as Domestic Representative
(Paper)

0.08

20

2

$29.80

$60.00

Request to Withdraw as Domestic Representative
(TEAS Global)

0.05

400

20

$29.80

$596.00

123,010

7,814

- - - - -

$240,226.00

Total

15.

- - - - -

Reason for Change in Burden

Summary of Changes Since the Previous Submission
The OMB approved this information collection on September 15, 2008, with 160,004
responses, 12,491 burden hours, and $7,317 in annualized (non-hour) costs.
With this renewal, the USPTO estimates that the total burden and annualized (nonhours) costs for this collection will be 123,010 responses, 10,927 burden hours, and
$2,526 in annualized costs, which is a reduction of 36,994 responses, 1,564 burden
hours, and $4,791 in annualized (non-hour) costs. These reductions are due to both
program changes and administrative adjustments.

10

Changes in Burden Estimates Since the 60-Day Federal Register Notice
In the 60-Day Federal Register Notice published on March 15, 2011, the USPTO
estimated that it would take ten minutes to complete the replacements of attorney of
record with another already appointed attorney submitted in paper and five minutes to
complete those submitted through TEAS. The USPTO estimated that one response
would be submitted for each of these items and that they would have a total of roughly
one burden hour for each of them. In this submission, the USPTO has reestimated the
completion times for the paper and TEAS versions at 30 minutes. However, since the
USPTO still estimates that only one response will be submitted for each of them, this
new estimated completion time does not affect the burden hours for these requirements.
Changes in Respondent Cost Burden
The annual respondent cost burden for this collection has decreased since the last
submission, despite the addition of six new items into this collection and an increase in
the hourly rate for attorneys. The USPTO still expects that attorneys are the most likely
to complete these submissions. In the previous submission, the hourly rate for
attorneys was $310, as reported in the 2007 report of the Committee on Economics of
Legal Practice of the American Intellectual Property Law Association. For this
submission, the USPTO is using the hourly rate of $325 reported in the 2009 report.
The USPTO estimates that the overall responses for this collection will decrease for this
renewal and will offset the costs for the new items being added into the collection and
the increase in the attorney hourly rate for the existing items. The USPTO estimates
that the annual respondent cost burden will decrease by $320,935, from $3,872,210 to
$3,551,275.
Changes in Responses and Burden Hours
The USPTO estimates that the number of responses submitted annually for this
collection will decrease by 36,994, from 160,004 to 123,010 responses per year. The
USPTO further estimates that the reduced submissions will decrease the total burden
hours for this collection by 1,564 hours, from 12,491 to 10,927 burden hours per year.
These changes are due to both program changes and administrative adjustments, as
follows:
•

The USPTO estimates that the number of revocations of attorney/domestic
representative and/or appointment of attorney/domestic representative filed in
paper will decrease during this renewal period. The USPTO estimates that the
number of submissions will decrease by 9,128 responses, from 13,128 to 4,000
responses per year. The USPTO estimates that this decrease will offset an
increase in the estimated completion time for these revocations from six to ten
minutes. The USPTO estimates that the total burden for this requirement will
decrease by 633 hours, from 1,313 to 680 hours per year. Therefore, this
collection takes a burden reduction of 633 hours as an administrative
adjustment.

11

•

The USPTO estimates that the number of revocations of attorney/domestic
representative and/or appointment of attorney/domestic representative submitted
through TEAS will decrease during this renewal period. The USPTO estimates
that the submissions will decrease by 25,023 responses, from 105,023 to 80,000
responses per year. As a result, the USPTO estimates that the total burden for
this requirement will decrease by 2,002 hours, from 8,402 to 6,400 burden hours
per year. Therefore, this collection takes a burden reduction of 2,002 hours
as an administrative adjustment.

•

The USPTO estimates that the number of requests for permission to withdraw as
the attorney of record filed in paper will decrease during this renewal period. The
USPTO estimates that the submissions will decrease by 202 responses, from 427
to 225 responses per year. As a result, the USPTO estimates that the total burden
for this requirement will decrease by 51 hours, from 107 to 56 burden hours per
year. Therefore, this collection takes a burden reduction of 51 hours as an
administrative adjustment.

•

The USPTO estimates that the number of requests for permission to withdraw as
the attorney of record submitted through TEAS will increase during this renewal
period. The USPTO estimates that the submissions will increase by 1,081
responses, from 3,419 to 4,500 responses per year. As a result, the USPTO
estimates that the total burden for this requirement will increase by 216 hours, from
684 to 900 hours per year. Therefore, this collection takes a burden increase
of 216 hours as an administrative adjustment.

•

The USPTO estimates that the number of change of owner’s addresses filed in
paper will decrease during this renewal period. The USPTO estimates that the
submissions will decrease by 2,623 responses, from 4,223 to 1,600 responses per
year. The USPTO estimates that this decrease will offset an increase in the
estimated completion time for these items from four to 10 minutes. The USPTO
estimates that the total burden for this requirement will decrease by 24 hours, from
296 to 272 hours per year. Therefore, this collection takes a burden reduction
of 24 hours as an administrative adjustment.

•

The USPTO estimates that the number of change of owner’s addresses filed
through TEAS will decrease during this renewal period. The USPTO estimates
that the submissions will decrease by 1,784 responses, from 33,784 to 32,000
responses per year. However, the USPTO also estimates that the time to
complete these items will increase from three to five minutes and that this will
offset the reduced submissions. Consequently, the USPTO estimates that the total
burden for this requirement will increase by 871 hours, from 1,689 to 2,560 hours
per year. Therefore, this collection takes a burden increase of 871 hours as
an administrative adjustment.

•

The USPTO has created a new TEAS Global form for change of domestic
representative’s address and is adding the TEAS and paper formats into the

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collection at this time. The USPTO estimates that it will take five minutes to
complete the change of domestic representative’s address through TEAS, and that
250 responses will be submitted per year for a total burden of 20 hours per year.
For the paper submissions, the USPTO estimates that it will take 10 minutes to
complete them, and that 13 responses will be submitted per year for a total burden
of 2 hours per year. Therefore, this collection takes a burden increase of 22
hours as a program change.
•

The USPTO has created a new TEAS Global form for the replacement of the
attorney of record with another already appointed attorney and is adding the TEAS
and paper formats into the collection at this time. The USPTO estimates that it will
take 30 minutes to complete these requests through TEAS and that 1 response will
be submitted for a total burden of 1 hour per year. The USPTO also estimates that
it will take 30 minutes to complete these requests in paper and that it will also have
1 response for a total burden of 1 hour per year. Therefore, this collection takes
a burden increase of 2 hours as a program change.

•

The USPTO has created a new TEAS Global form for the requests to withdraw as
domestic representative and is adding the TEAS and paper formats into the
collection at this time. The USPTO estimates that it will take 5 minutes to complete
these requests through TEAS and that 400 responses will be submitted per year
for a total burden of 32 hours per year. The USPTO estimates that it will take 10
minutes to complete these requests in paper and that 20 responses will be
submitted per year for a total burden of 3 hours per year. Therefore, this
collection takes a burden increase of 35 hours as a program change.

The USPTO estimates that a net total of 1,564 burden hours will be reduced from this
collection, from 12,491 to 10,927 burden hours per year. The USPTO estimates that 59
burden hours per year will be added to the collection due to program changes. The
USPTO also estimates that 1,087 burden hours per year will be added to the collection
as a result of administrative adjustments, but that this increase will be offset by a
reduction of 2,710 burden hours, for a total reduction of 1,623 burden hours per year
due to administrative adjustments. The USPTO estimates that this decrease will offset
the increase due to the program changes. Therefore, this information has a net
burden decrease of 1,564 hours, with an increase of 59 hours due to program
changes and a reduction of 1,623 hours due to administrative adjustments.
Changes in Annual (Non-Hour) Costs
For this renewal, the USPTO estimates that the annual (non-hour) costs for this
collection will decrease by $4,791, from $7,317 to $2,526 per year. This change is due
to both program changes and administrative adjustments, as follows:
•

The USPTO estimates that the postage costs for the paper submissions of the
revocation of attorney/domestic representative and/or appointment of
attorney/domestic representative will decrease during this renewal period. The

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USPTO estimates that the postage costs will decrease by $3,678, from $5,403 to
$1,725 per year. The USPTO estimates that the number of mailed submissions
will decrease by 8,945 responses, from 12,865 to 3,920 responses per year and
that this decrease offsets the increase in the first-class postage rates from 42 to 44
cents. Therefore, this collection has a reduction of $3,678 in annual (nonhour) postage costs due to an administrative adjustment.
•

The USPTO estimates that the postage costs for the paper submissions of the
requests for permission to withdraw as the attorney of record will decrease during
this renewal period. The USPTO estimates that the postage costs will decrease by
$79, from $176 to $97 per year. The USPTO estimates that the number of mailed
submissions will decrease by 197 responses, from 418 to 221 responses per year
and that this decrease offsets the increase in the first-class postage rates from 42
to 44 cents. Therefore, this collection has a reduction of $79 in annual (nonhour) postage costs due to an administrative adjustment.

•

The USPTO estimates that the postage costs for the paper submissions of the
change of owner’s address form will decrease during this renewal period. The
USPTO estimates that the postage costs will decrease by $1,048, from $1,738 to
$690 per year. The USPTO estimates that the number of mailed submissions will
decrease by 2,571 responses, from 4,139 to 1,568 responses per year and that
this decrease offsets the increase in the first-class postage rates from 42 to 44
cents. Therefore, this collection has a reduction of $1,048 in annual (nonhour) postage costs due to an administrative adjustment.

•

In addition to the TEAS Global forms for the change to domestic representative’s
address form, the replacement of attorney of record with another already appointed
attorney, and request to withdraw as domestic representative, the USPTO is also
adding the paper formats for these requirements into the collection at this time.
The USPTO estimates that these items will be mailed to the USPTO using the firstclass postage rate of 44 cents. The USPTO estimates that 12 changes of
domestic representative’s addresses, 1 replacement of attorney of record with
another already appointed attorney, and 19 requests to withdraw as domestic
representatives will be mailed to the USPTO per year, for a total postage cost of
$14 per year. Therefore, this collection has an increase of $14 in annual (nonhour) postage costs due to program changes.

The USPTO estimates that the annual (non-hour) costs for this collection will decrease
by $4,791, from $7,317 to $2,526 per year. The USPTO estimates that $14 will be
added to this collection as a result of program changes. However, the USPTO
estimates that this increase will be offset by a reduction of $4,805 due to administrative
adjustments. Therefore, this information collection has a net total reduction of
$4,791 in annual (non-hour) costs, with an increase of $14 due to program
changes offset by a decrease of $4,805 due to administrative adjustments.

14

16.

Project Schedule

The USPTO does not intend to publish this information for statistical use.
17.

Display of Expiration Date of OMB Approval

The forms in this information collection will display the OMB Control Number and the
date on which OMB’s approval of this information collection expires.
18.

Exception to the Certificate Statement

This collection of information does not include any exceptions to the certificate
statement.
B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection of information does not employ statistical methods.

LIST OF REFERENCES
A.
B.
C.
D.
E.
F.
G.

USPTO Information Quality Guidelines
TEAS Revocation of Attorney/Domestic Representative and/or Appointment of
Attorney/Domestic Representative (PTO Form 2196)
TEAS Request for Permission to Withdraw as Attorney of Record (PTO Form 2201)
TEAS Change of Owner’s Address (PTO Form 2197)
Change of Domestic Representative’s Address (TEAS Global Form)
Replacement of Attorney of Records with Another Already Appointed Attorney (TEAS
Global Form)
Request to Withdraw as Domestic Representative (TEAS Global Form)

15