Commentary on Notice of Proposed Rules to Implement Post Grant Patent Proceedings Due on Monday

The deadlines for submitting comments to the USPTO on the Group 2 rule making proposals (i.e., post grant patent proceedings) are next Monday and Tuesday, April 9-10th. (depending upon the publication date)

While the USPTO should be applauded for their monumental, and comprehensive proposals (most of which are quite good and well thought out), some issues are still to be refined. The most problematic issues presented by the proposed rules, at least in my opinion, are as follows:

1. Page Limits (and here)
2. Fee Structure
3. Patentee Estoppel
4. Supplemental Information