USIJ Comments on USPTO Initiatives to Ensure the Robustness and Reliability of Patent Rights

Dear Director Vidal, The Alliance of U.S. Startups & Inventors for Jobs (USIJ) respectfully submits this response to your Request for Comments on USPTO Initiatives to Ensure the Robustness and Reliability of Patent Rights.

USIJ is a coalition of over 20 startup companies, along with their investors, executives, inventors, and affiliated research institutions, that have developed numerous breakthrough technologies. The success of these small firms is a direct consequence of the strength of the U.S. patent system, which for more than 200 years has rewarded entrepreneurs who turn unproven ideas into products that change the world.

Our coalition is dedicated to advancing policies that further reinforce and strengthen this system. We are concerned that many of the proposals in the RFC will do the opposite.

From the beginning, the RFC seems to question the quality of the U.S. patent system. The title implies that current patent rights are not "robust," nor "reliable." USPTO's questions suggest the patent system is fundamentally flawed.3 One might understandably think, after reading the document in its entirety, that patent rights are in need of a complete overhaul.

We disagree.