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Chapter 400

Representative of Applicant or Owner

Chapter 400 covers who may represent applicants before the USPTO, who qualifies as the applicant, power of attorney rules, assignee rights, and practitioner certifications. Under AIA, the assignee can be the applicant — which changes who controls prosecution.


Core Concepts

Who Is the Applicant Under AIA, applicant may be: inventor(s), legal representative of deceased/incapacitated inventor (37 CFR 1.43), joint inventors acting for omitted inventor (37 CFR 1.45), or assignee/obligated assignee (37 CFR 1.46). If applied under 1.46, assignee — NOT inventor — is the applicant.

Deceased or Incapacitated Inventor — 37 CFR 1.43 Legal representative (executor, administrator, guardian) may apply and becomes the applicant.

Joint Inventors — Omitted Inventor — 37 CFR 1.45 If one inventor refuses to sign, cannot be found, or refuses to cooperate — remaining inventors may apply. Omitted inventor still named but need not sign.

Assignee as Applicant — 37 CFR 1.46 (Extremely Important) Assignee may file as applicant if invention assigned, obligated to assign, or sufficient proprietary interest shown. Consequences: inventor cannot appoint attorney, inventor cannot revoke POA, assignee controls prosecution.

Power of Attorney — MPEP 402 POA must be signed by the applicant. When multiple applicants, ALL applicants must sign — one applicant cannot appoint POA alone without petition and fee showing sufficient cause. Non-applicant assignee CANNOT appoint attorney.

  • Inventor-applicant: YES (all inventors must sign)
  • Assignee-applicant under 1.46: YES
  • Assignee NOT applicant: NO

Assignee Rights — 37 CFR 3.71/3.72/3.73 3.71: Defines when assignee becomes owner of record — requires recorded assignment. 3.72: Assignee may prosecute only after ownership established. 3.73: Assignee must establish ownership before acting — merely owning is not enough. Requires 3.73(c) statement. Distinction: Assignee-applicant under 1.46 may appoint attorney directly. Mere assignee owner must comply with 3.71 and 3.73 first.

Continuing Applications and POA POA from parent carries over to continuation UNLESS continuing application names an inventor not named in prior application.

Practitioner Not of Record — MPEP 405 May file papers under 37 CFR 1.34. Filing paper = authorization for that filing only. Filing paper does NOT authorize interviews — must submit interview request form separately.

Withdrawal of Attorney — MPEP 409 Requires USPTO approval. USPTO will NOT decide withdrawal requests filed after reply period expired. Withdrawing attorney may only redirect correspondence to: applicant, proper assignee, or recognized address — cannot redirect to another law firm.

Certifications and Sanctions — 37 CFR 11.18(b) Every paper submitted certifies: not filed for improper purpose, legal contentions warranted, factual allegations supported, statements made after reasonable inquiry. Violations may result in sanctions.

PTO Forms Certification language on USPTO forms CANNOT be modified or altered.


Key Rules

1.Under 37 CFR 1.46 assignee BECOMES the applicant — inventor loses right to appoint or revoke POA
2.POA must be signed by ALL applicants — one applicant cannot appoint alone without petition and fee
3.Non-applicant assignee cannot appoint attorney
4.37 CFR 3.73 statement required before assignee can act — ownership must be established
5.Remaining inventors can proceed without missing inventor under 37 CFR 1.45
6.Practitioner filing under 1.34 may file papers but NOT automatically conduct interviews
7.Withdrawal requests filed after reply period expired will not be treated on merits
8.37 CFR 11.18(b) — every filed paper certifies reasonable inquiry and proper purpose
9.POA carries over to continuation UNLESS new inventor added in continuing application

EXAM TIP

Two most tested concepts: (1) Under 37 CFR 1.46 the assignee BECOMES the applicant — inventor loses the right to appoint or revoke POA. (2) POA must be signed by ALL applicants — if there are joint inventors/applicants, one cannot appoint without all signing, unless a petition with fee and sufficient cause is filed.


Common Traps

1.Thinking inventor can always appoint or revoke POA — if assignee is applicant under 1.46, inventor loses this right
2.Thinking one applicant can appoint POA alone when multiple applicants exist — all must sign
3.Confusing assignee-applicant (1.46) with mere assignee owner — owner must establish ownership under 3.73 first
4.Assuming practitioner filing papers under 1.34 is authorized to conduct interviews — not the same
5.Missing the continuing application POA exception — POA does not carry over if new inventor added
6.Thinking withdrawal can be filed at any time — USPTO will not consider after reply period expired

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Sections

401U.S. Patent and Trademark Office Cannot Aid in Selection of Patent Practitioner
402Power of Attorney; Naming Representative
High Yield
403Correspondence — With Whom Held; Customer Number Practice
405Interviews With Patent Practitioner Not of Record
High Yield
406Death of Patent Practitioner
407Suspended or Excluded Patent Practitioner
408Interviews With Patent Practitioner of Record
409Death, Legal Incapacity, or Unavailability of Inventor
High Yield
410Representations to the U.S. Patent and Trademark Office