Two challenges to USPTO proposed rule on IDS
Of the one by Richard Belzer, Boundy writes:
Dr. Belzer gets down to some decidedly non-bureaucratic truth-telling:
“Executive Order 12,866. Based on my expertise in regulatory analysis, and more than 20 years’ experience reviewing such analyses (including 10 while employed as an economist at OMB), I am virtually certain that the proposed IDS Rule is economically significant ...
“Furthermore, based on my governmental experience it is inconceivable that USPTO could be unaware of the approximate magnitude of these costs, or that it employed any reasonable economic method or logic to determine that the proposed rule was 'not significant'. ... One can infer with reasonable certainty that USPTO deliberately evaded the requirements of Executive Order 12,866.