The burdens imposed by the USPTO's new rules on continuing applications
First, applicants must identify (in every pending application) every commonly-owned application or patent that names at least one inventor in common and was filed or claims priority to an application that was filed within two months of the subject application. Second, for every commonly-owned patent application sharing a common inventor and "substantially overlapping" subject matter, a rebuttable presumption will arise that there is at least one patentably-indistinct claim in each application (using a one-way obviousness test) (see new rules notice, p. 46,785).
Noonan mentions the IPO survey: The Intellectual Property Owners (IPO) posted yesterday on their website the results of a survey of 37 member organizations relating to the extent of the burden these new rules would impose. (...)the [PTO]'s acknowledgement of the justification of IPO's and BIO's complaints appears to contradict their representations to the Office of Management and Budget (and that Office's subsequent decision) that the rules imposed no significant economic impact.
Noonan suggests action by the patent community to point out the problems with the rules: This track record suggests that members of the patent community, including the patent bar, had better get busy if they will have any hope of adequately protecting U.S. patent rights in the face of a Patent Office administration that seems openly hostile.
Noonan's blink post contains links to other relevant posts he has made on the new rules.
Separately, James McEwan summarizes some of strategic pre-November responses, and patently-o has Rule Changes Triage.