| 1. | An IR holder should be able to appoint a domestic representative as soon as the request for extension of protection is granted a serial number. |
| 2. | Proposed Rule 7.11 sets forth the requirements for international applications originating from the U.S. 7.11(a)(2) requires that the name and address of the international applicant be identical to the name and address of the applicant or registrant as they appear in the basic application or basic registration. The requirement with respect to the registrant's address should be deleted. In order to update the registrant's address, it is necessary for the registrant to file a Request for Correction of Registration Certificate, for which there is a $100 fee and a processing time of approximately 9-10 months. Since identity of the international applicant's address with the address reflected in the basic registration does not appear to be required by the Madrid Protocol, this requirement should be deleted from the final rules. |
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Respectfully submitted, Allison Strickland |
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