2020/9/14

FormSG

2020/9/14

FormSG

Before you provide your responses, please let us have your name, e-mail address, thename of your organisation (if applicable) and your designation in your organisation (ifapplicable). We may contact you for follow-up questions, if necessary.

1.

Name
Tatsuya MORI

Public Consultation on Changes toSimplify Intellectual Property
Processes and Improve User
Experience with Digital Initiatives

2.

Email addressnagano@jipa.or.jp

3.

 60 mins estimated time to complete

Organisation(optional)

Japan Intellectual Property Association (JIPA)

4.

Instructions

Designation in your organisation(optional)

Managing Director (Patent in Southeast Asia)

IPOS is conducting a public consultation on the proposed changes to simplify
and streamline Intellectual Property ("IP") processes and improve user
experience with digital initiatives. The public consultation period is from 17

General Note

August (Monday) to 14 September 2020 (Monday). An extension of the

Please note that toggling between Yes/No will result in your responses being deleted.
Should you need to change your selection, please ensure that you have saved yourresponses.

consultation period is not possible.
The public consultation paper can be accessed athttps://www.ipos.gov.sg/docs/default-source/resources-library/ipos-public-

5.

consultation-august-2020.pdf (https://www.ipos.gov.sg/docs/default-

I am answering questions in relation to

A: Simplifying and Streamlining of Patents Processes (3 sets of questions)source/resources-library/ipos-public-consultation-august-2020.pdf).

 NO
Please tell us about yourself

6.

 YES

I am answering questions in relation to

B: Simplifying and Streamlining of Trade Marks Processes (2 sets of questions)
https://form.gov.sg/#!/5f2c1858d6f2b00011ffb316

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2020/9/14

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 NO

2020/9/14

We don't think the two-month period is long enough.
For non-English speaking foreign applicants, it may take sometime to prepare the translation, so a period of about 3 months
ld b b tt f

 YES

I am answering questions in relation to7.

C: Simplifying and Streamlining of Common Processes (3 sets of questions)

 NO

11.

Question A2. Examination review(optional)a) Are you supportive of this proposed change? Please elaborate with reason(s).

 YESYes. We are supportive of the proposal, because the revised
content will be reviewed by the examiner.

I am answering questions in relation to

8.

FormSG

D: Improving User Experience with Digital Initiatives (1 set of question)

 NO

 YES

12.

Question A2. Examination review(optional)b) What are your considerations when deciding if you wish to submit amendments andwritten submissions or only written submissions during the examination review stage?

A: SIMPLIFYING AND STREAMLINING PATENTSPROCESSES
Question A1. Examiner-initiated informal communication

9.

When the examiner receive such as amendments and written
submissions, we would appreciate it if the examiner could take
into account the content of the amendment and con rm whether
t th
t t h
i th
i ti
t

(optional)a) Are you supportive of this proposed process? Please elaborate with reason(s).

13.

(optional)c) Based on the current examination review process, where the applicant les written
submissions and amendments during the request for an examination review, it isapparent that the applicant intends to amend the application to overcome theobjections in the earlier examination report. While the examiner has to provide an
opinion on whether he agrees/disagrees with the earlier examination report during theexamination review, what are the applicant’s reason(s) for seeking this opinion?

Yes. We are supportive of the proposed process from the view ofthe procedure simpli cation.

10.

Question A2. Examination review

Question A1. Examiner-initiated informal communication

One of the purposes of the applicant is to con rm whether theexaminer's recognition is the same as the applicant's
recognition.
Il ti t A2 b)
d
t
ft
d
di t

(optional)b) If supportive, is 2 months a reasonable period for the applicant to submit the
response following an examiner-initiated informal communication? If no, please propose
a period and provide us with the rationale.

Question A3. Publication of translation of international
application (optional)
14.

a) Are you supportive of this proposed change? Please elaborate with reason(s).
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18.

Yes.

Question C2. Amendments, corrections, recti cations(optional)a) Do you agree that the proposed corrections relating to priority details and name of
applicant which results in a change in IP ownership should be advertised? Pleaseelaborate with reason(s).

The contents of the proposal are very useful for applicants for
simplifying the procedure.

This change might be great for users. Because it is possible for athird party to make an objection after con rming the content.

Question A3. Publication of translation of international
application (optional)
15.

b) If supportive, how do you think the process can be simpli ed?
19.

It would be greatly appreciated if you provide a new formats that
include both Patents Form 37 and Patents Form 38.

Question C2. Amendments, corrections, recti cations(optional)b) Are there any other proposed corrections that you think should be advertised? Pleaseelaborate with reason(s).

Related to question c）, We feel that two months is short.

C: SIMPLIFYING AND STREAMLINING COMMONPROCESSES
20.

Question C1. Relief measures for Trade Mark and Registered
Design applications (optional)
16.

Question C2. Amendments, corrections, recti cations(optional)c) Is 2 months a reasonable period for advertisement? If no, please propose a period
and provide us with the rationale.

a) Are you supportive of the proposed changes? Please elaborate with reason(s).

We would appreciate it if you could consider extending the period（ex.3 months）.

Question C3. Application for registration of transactions for IP
rights (optional)
21.

Question C1. Relief measures for Trade Mark and Registered
Design applications (optional)
17.

a) Are you supportive of the proposal to streamline the de nition of “relevant parties”
across the Trade Marks, Registered Designs and Patents legislation? Please elaborate
with reason(s).

b) Would you have any re nements to the proposed changes? If yes, please elaborate.

Yes. We think the de nition shown in 3.4 is reasonable and valid.

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2020/9/14

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2020/9/14

Question C3. Application for registration of transactions for IP
rights (optional)

FormSGSUBMIT

22.

b) Do you have any re nement(s) to the proposed changes? If yes, please elaborate.

We are concerned that there are multiple interpretations of thede nition of “bene ciary of an assent”. Therefore, we would
appreciate it if you could clarify the de nition a little more.
POWERED BY

D: IMPROVING USER EXPERIENCE ANDSERVICE WITH DIGITAL INITIATIVESreCAPTCHA で保護されていますQuestion D1. Use of Arti cial Intelligence technologies indecision making (optional)
23.

プライバシー - 利⽤規約a) Are the safeguard measures described in each example above suf cient? If not, what
are your concerns, and what other operational and/or legislative safeguard measureswould you deem necessary in the adoption of decision making by AI?

We think it is a very advanced and wonderful attempt.In
particular, we strongly support the use of AI for translation of
speci cations as shown in 1.2, patent classi cation, and
t d
ki
hi 13
Question D1. Use of Arti cial Intelligence technologies indecision making (optional)
24.

b) While IPOS will carry out due diligence and conduct rigorous testing before rollingout AI solutions, are there other speci c areas you think should be paid attention to? If
so, please elaborate on the reasons and also possible measures.

When you adopt the AI solutions to IP eld, the following areas
are speci c area.
Ex.Judgment of inventive step of patent, Judgment of wellk
ft d
k J d
t f i il it f i d t i l d i

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Question
Question A1a) Are you supportive of this proposed process? Please elaborate with reason(s).

Comment
Yes. We are supportive of the proposed process from the view of the procedure
simplification.

b) If supportive, is 2 months a reasonable period for an applicant to submit
the response following an examiner-initiated informal communication?
If no, please propose a period and provide us with the rationale.

We don't think the two-month period is long enough.
For non-English speaking foreign applicants, it may take some time to prepare thetranslation, so a period of about 3 months would be better for us.

Question A2a) Are you supportive of this proposed change? Please elaborate with reason(s).

Yes. We are supportive of the proposal, because the revised content will be reviewed
by the examiner.

b) What are your considerations when deciding if you wish to submit
amendments and written submissions or only written submissions during
the examination review stage?

When the examiner recieve such as amendments and written submissions, we would
appreciate it if the examiner could take into account the content of the amendment
and confirm whether or not the content shown in the examination report wasappropriate. (Reason: It might be possible to confirm the intention ofamendments,written submission etc.).

c) Based on the current examination review process, where an applicant files
written submissions and amendments during the request for an examination
review, it is apparent that the applicant intends to amend the application to
overcome the objections in the earlier examination report.
While the examiner has to provide an opinion on whether he agrees/disagrees
with the earlier examination report during the examination review, what are theapplicant’s reason(s) for seeking this opinion?

One of the purposes of the applicant is to confirm whether the examiner's recognitionis the same as the applicant's recognition.

Question A3a) Are you supportive of this proposed change? Please elaborate with reason(s).

Yes.
The contents of the proposal are very useful for applicants for simplifying theprocedure.

b) If supportive, how do you think the process can be further simplified?

It would be greatly appreciated if you provide a new formats that include both Patents
Form 37 and Patents Form 38.

Question C2a) Do you agree that the proposed corrections relating to priority details andname of applicant which result in a change in IP ownership should be
advertised? Please elaborate with reason(s).

This change might be great for users. Because it is possible for a third party to makean objection after confirming the content.

In relation to A2 b), amendments are often made according to the content of theexaminar report, so it is useful for the examiner and the applicant if it is possible toconfirm whether the examiner's recognition is the same as the applicant's recognition
about the earlier examination report.

b) Are there any other proposed corrections that you think should be
advertised? Please elaborate with reason(s).

Related to question c）, We feel that two months is short.

c) Is 2 months a reasonable period for advertisement? If no, please propose
a period and provide us with the rationale.

We would appreciate it if you could consider extending the period（ex.3 months）.

Question C3a) Are you supportive of the proposal to streamline the definition of “relevant
parties” across the Trade Marks, Registered Designs and Patents
legislation? Please elaborate with reason(s).

Yes. We think the definition shown in 3.4 is reasonable and valid.

b) Do you have any refinement(s) to the proposed changes? If yes, pleaseelaborate.

We are concerned that there are multiple interpretations of the definition of“beneficiary of an assent”. Therefore, we would appreciate it if you could clarify thedefinition a little more.

Question D1
We think it is a very advanced and wonderful attempt.In particular, we stronglya) Are the safeguard measures described in each example above sufficient? If not, support the use of AI for translation of specifications as shown in 1.2, patent
what are your concerns, and what other operational and/or legislative safeguard
classification, and trademark image search in 1.3.
measures would you deem necessary in the adoption of decision making by AI?
On the other hand, there are some concerns about using AI for examination.
Specifically,when you adopt the AI solutions to examine patents, we areconcerned that there may be differences in the examination's results between AI and
the examiner.If there is the difference,We think that it affects the quality of rights.
Therefore, as you have planned,we appleciate that you conduct a verification test inadvance and check whether the examination criteria between AI and humans match.
And we would also appreciate if you consider to make a system for the quality of
examination, such as checking by an examiner at the beginning of the introduction.

b) While IPOS will carry out due diligence and conduct rigorous testing before
rolling out AI solutions, are there other specific areas you think that should be
paid attention to? If so, please elaborate on the reasons and also possible
measures.

When you adopt the AI solutions to IP field, the following areas are specific area.
Ex.Judgment of inventive step of patent, Judgment of well-known of trademark,Judgment of similarity of industrial design.
Because it is required some experience for examination.
As a countermeasure, we think it is important to conduct a verification test andconfirm that sufficient accuracy can be expected.
In addition, it is also known that the accuracy of AI engine recognition changes overtime.The result of prior patent search is an important factor for judging
novelty/inventive step, but if it changes, it may affect the examination. Therefore,
please conduct a careful examination through demonstration experiments.

2020/9/14

FormSG

2020/9/14

FormSG

Before you provide your responses, please let us have your name, e-mail address, thename of your organisation (if applicable) and your designation in your organisation (ifapplicable). We may contact you for follow-up questions, if necessary.

1.

Name
Makoto FUKUOKA

Public Consultation on Changes toSimplify Intellectual Property
Processes and Improve User
Experience with Digital Initiatives

2.

Email addressnagano@jipa.or.jp

3.

 60 mins estimated time to complete

Organisation(optional)

Japan Intellectual Property Association (JIPA)

4.

Instructions

Designation in your organisation(optional)

Managing Director (Design)

IPOS is conducting a public consultation on the proposed changes to simplify
and streamline Intellectual Property ("IP") processes and improve user
experience with digital initiatives. The public consultation period is from 17

General Note

August (Monday) to 14 September 2020 (Monday). An extension of the

Please note that toggling between Yes/No will result in your responses being deleted.
Should you need to change your selection, please ensure that you have saved yourresponses.

consultation period is not possible.
The public consultation paper can be accessed athttps://www.ipos.gov.sg/docs/default-source/resources-library/ipos-public-

5.

consultation-august-2020.pdf (https://www.ipos.gov.sg/docs/default-

I am answering questions in relation to

A: Simplifying and Streamlining of Patents Processes (3 sets of questions)source/resources-library/ipos-public-consultation-august-2020.pdf).

 NO
Please tell us about yourself

6.

 YES

I am answering questions in relation to

B: Simplifying and Streamlining of Trade Marks Processes (2 sets of questions)
https://form.gov.sg/#!/5f2c1858d6f2b00011ffb316

1/6

https://form.gov.sg/#!/5f2c1858d6f2b00011ffb316

2/6

2020/9/14

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 NO

2020/9/14

11.

 YES

 YES

I am answering questions in relation to

8.

12.

D: Improving User Experience with Digital Initiatives (1 set of question)

 NO

Question C2. Amendments, corrections, recti cations(optional)b) Are there any other proposed corrections that you think should be advertised? Pleaseelaborate with reason(s).

 YESNo, there are not any other proposed corrections.

C: SIMPLIFYING AND STREAMLINING COMMONPROCESSES
13.

Question C2. Amendments, corrections, recti cations(optional)c) Is 2 months a reasonable period for advertisement? If no, please propose a period
and provide us with the rationale.

Question C1. Relief measures for Trade Mark and Registered
Design applications (optional)
9.

2-months is a reasonable period for advertisement.

a) Are you supportive of the proposed changes? Please elaborate with reason(s).

We are supportive of the proposed changes. Because theproposed period to reinstate for design registration is equal to or
longer than that of other countries, we believe that the twoth i
f i t f th
i t t
t
i d

Question C3. Application for registration of transactions for IP
rights (optional)
14.

Question C1. Relief measures for Trade Mark and Registered
Design applications (optional)
10.

a) Are you supportive of the proposal to streamline the de nition of “relevant parties”
across the Trade Marks, Registered Designs and Patents legislation? Please elaborate
with reason(s).

b) Would you have any re nements to the proposed changes? If yes, please elaborate.

Yes, we are supportive of the proposal.

No, we do not have any re nements to the proposed changes.

https://form.gov.sg/#!/5f2c1858d6f2b00011ffb316(optional)

Yes, we agree that the proposed corrections relating to priority
details and name of applicant which result in a change in IP
ownership should be advertised because third parties would be
bl t htht it tthti

C: Simplifying and Streamlining of Common Processes (3 sets of questions) NO

Question C2. Amendments, corrections, recti cationsa) Do you agree that the proposed corrections relating to priority details and name of
applicant which results in a change in IP ownership should be advertised? Pleaseelaborate with reason(s).

I am answering questions in relation to

7.

FormSG

3/6

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4/6

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2020/9/14

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Question C3. Application for registration of transactions for IP
rights (optional)
15.

b) Do you have any re nement(s) to the proposed changes? If yes, please elaborate.

No, we do not have any re nement(s) to the proposed changes.

POWERED BY

D: IMPROVING USER EXPERIENCE ANDSERVICE WITH DIGITAL INITIATIVESreCAPTCHA で保護されています
プライバシー - 利⽤規約

Question D1. Use of Arti cial Intelligence technologies indecision making (optional)
16.

a) Are the safeguard measures described in each example above suf cient? If not, what
are your concerns, and what other operational and/or legislative safeguard measureswould you deem necessary in the adoption of decision making by AI?

In the current situation where the accuracy of examination by AI
is unknown, we are concerned about AI making decisions on
design registration.
I AI b
d
i ti
if th
i i
t th
Question D1. Use of Arti cial Intelligence technologies indecision making (optional)
17.

b) While IPOS will carry out due diligence and conduct rigorous testing before rollingout AI solutions, are there other speci c areas you think should be paid attention to? If
so, please elaborate on the reasons and also possible measures.

So far, we don't have any speci c idea now.

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Question
Question C1a) Are you supportive of the proposed changes? Please elaborate with reason(s).

Comment
We are supportive of the proposed changes. Because the proposed period toreinstate for design registration is equal to or longer than that of other countries,
we believe that the two months is sufficient for the reinstatement period.

b) Would you have any refinements to the proposed changes? If yes, pleaseelaborate.

No, we do not have any refinements to the proposed changes.

Question C2a) Do you agree that the proposed corrections relating to priority details andname of applicant which result in a change in IP ownership should be
advertised? Please elaborate with reason(s).

Yes, we agree that the proposed corrections relating to priority details and name of
applicant which result in a change in IP ownership should be advertised because
third parties would be able to have the opportunity to oppose the correction.

b) Are there any other proposed corrections that you think should be
advertised? Please elaborate with reason(s).

No, there are not any other proposed corrections.

c) Is 2 months a reasonable period for advertisement? If no, please propose
a period and provide us with the rationale.

2-months is a reasonable period for advertisement.

Question C3a) Are you supportive of the proposal to streamline the definition of “relevant
parties” across the Trade Marks, Registered Designs and Patents
legislation? Please elaborate with reason(s).

Yes, we are supportive of the proposal.

b) Do you have any refinement(s) to the proposed changes? If yes, pleaseelaborate.

No, we do not have any refinement(s) to the proposed changes.

Question D1a) Are the safeguard measures described in each example above sufficient? If not,what are your concerns, and what other operational and/or legislative safeguard
measures would you deem necessary in the adoption of decision making by AI?

・ In the current situation where the accuracy of examination by AI is unknown, weare concerned about AI making decisions on design registration.
-In AI-based examinations, if there are revisions to the examination guidelines orchanges in judicial precedents, we would like IPOS to make AI-based decisions
based on those changes.
・ From the applicant's point of view, we would like IPOS to send us a notificationthat logically explains the reason for the decision by AI.
For example, we need a logical explanation as to why an application design wasdetermined to be non-novelty in its similarity to previous designs.

b) While IPOS will carry out due diligence and conduct rigorous testing before
So far, we don't have any specific idea now.
rolling out AI solutions, are there other specific areas you think that should be paid
attention to? If so, please elaborate on the reasons and also possible measures.

2020/9/14

FormSG

2020/9/14

FormSG

Before you provide your responses, please let us have your name, e-mail address, thename of your organisation (if applicable) and your designation in your organisation (ifapplicable). We may contact you for follow-up questions, if necessary.

1.

Name
Koji SAITO

Public Consultation on Changes toSimplify Intellectual Property
Processes and Improve User
Experience with Digital Initiatives

2.

Email addressnagano@jipa.or.jp

3.

 60 mins estimated time to complete

Organisation(optional)

Japan Intellectual Property Association (JIPA)

4.

Instructions

Designation in your organisation(optional)

Managing Director (Trademark)

IPOS is conducting a public consultation on the proposed changes to simplify
and streamline Intellectual Property ("IP") processes and improve user
experience with digital initiatives. The public consultation period is from 17

General Note

August (Monday) to 14 September 2020 (Monday). An extension of the

Please note that toggling between Yes/No will result in your responses being deleted.
Should you need to change your selection, please ensure that you have saved yourresponses.

consultation period is not possible.
The public consultation paper can be accessed athttps://www.ipos.gov.sg/docs/default-source/resources-library/ipos-public-

5.

consultation-august-2020.pdf (https://www.ipos.gov.sg/docs/default-

I am answering questions in relation to

A: Simplifying and Streamlining of Patents Processes (3 sets of questions)source/resources-library/ipos-public-consultation-august-2020.pdf).

 NO
Please tell us about yourself

6.

 YES

I am answering questions in relation to

B: Simplifying and Streamlining of Trade Marks Processes (2 sets of questions)
https://form.gov.sg/#!/5f2c1858d6f2b00011ffb316

1/8

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2/8

2020/9/14

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 NO

2020/9/14

FormSG

We consider that speed, cost and clarity in examination decisions

 YES

are the key priority in the course of Trade Mark registration.

I am answering questions in relation to7.

C: Simplifying and Streamlining of Common Processes (3 sets of questions)

 NO

11.

 YES

c) If you have a partially refused application, will you be more inclined to (i) proceedwith an amendment as proposed by the Registrar; (ii) initiate an amendment form (andrelevant fee) to remove the objectionable goods and/or services; or (iii) wait for the
stipulated timelines to lapse and automatically proceed to the next processing stage?
Please provide reason(s) for your option.

I am answering questions in relation to

8.

Question B1. Partial refusal mechanism for national applications(optional)

D: Improving User Experience with Digital Initiatives (1 set of question)

 NO

We will be more inclined to wait for the stipulated deadlines tolapse and automatically proceed to the next processing stage
because of the cost-saving.

 YES

B: SIMPLIFYING AND STREAMLINING TRADEMARKS PROCESSES

12.

d) If objectionable goods and/or services are stated upfront in the examination report ina partially refused application, will you be more inclined to divide out the objectionableportion(s) of the application? Please provide reason(s) for doing/not doing so.

Question B1. Partial refusal mechanism for national applications

9.

Question B1. Partial refusal mechanism for national applications(optional)(optional)a) Do you agree with the adoption of the “partial refusal” mechanism for the national
Trade Mark regime? Please elaborate with reason(s).

Yes, we agree with the adoption of the “partial refusal”
mechanism for the national Trade Mark regime because we canhave several options to pursue our partially refused application
d
di
th
t
f th bj ti ( )
10.

13.

(optional)a) Do you generally vary the use of your Trade Marks (such as differences in colour,
capitalisation, or positioning of elements) in the course of trade? If so, how?

Question B1. Partial refusal mechanism for national applications(optional)

No, we do not generally vary the use of our Trade Marks.

b) What is/are the key priority you consider in the course of Trade Mark registration?
(e.g., speed, cost, speci city in relation to objectionable goods and/or services, clarity in
examination decisions)

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Question B2. Series of Trade Marks

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2020/9/14

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14.

Question B2. Series of Trade Marks

2020/9/14(optional)

No, we do not have any re nements to the proposed changes.

Are you supportive of the proposals to limit the maximum number and/or type of marksthat can be led in a single application? Please elaborate with reason(s).

Yes, we are supportive of the proposals to limit the maximum
number and/or type of marks that can be led in a single
application because we think that capping the number of marks
i
i t 4
bl
15.

Question B2. Series of Trade Marks

FormSG

18.

Question C2. Amendments, corrections, recti cations(optional)a) Do you agree that the proposed corrections relating to priority details and name of
applicant which results in a change in IP ownership should be advertised? Pleaseelaborate with reason(s).

(optional)

Yes, we agree that the proposed corrections relating to priority
details and name of applicant which result in a change in IP
ownership should be advertised because the proposed changes
h l
t
t t
d
t i t t thb) Which part of the Trade Marks Registry’s Work Manual Chapter on "Series of Marks"
do you nd most useful and relevant for reference? Which part(s) do you nd the mostcomplex? Do you have any suggestion(s) on how the Chapter can be improved to betterthe understanding of the requirements for series marks?

19.

Question C2. Amendments, corrections, recti cations(optional)b) Are there any other proposed corrections that you think should be advertised? Pleaseelaborate with reason(s).

No, there are not any other proposed corrections.

C: SIMPLIFYING AND STREAMLINING COMMONPROCESSES
Question C1. Relief measures for Trade Mark and Registered
Design applications (optional)
16.

20.

Question C2. Amendments, corrections, recti cations(optional)c) Is 2 months a reasonable period for advertisement? If no, please propose a period
and provide us with the rationale.

a) Are you supportive of the proposed changes? Please elaborate with reason(s).

We are supportive of the proposed changes because we canreinstate a trademark application which is treated as withdrawn
due to irresistible forces.

2-months is a reasonable period for advertisement.

17.

Question C1. Relief measures for Trade Mark and Registered
Design applications (optional)

21.

b) Would you have any re nements to the proposed changes? If yes, please elaborate.

a) Are you supportive of the proposal to streamline the de nition of “relevant parties”
across the Trade Marks, Registered Designs and Patents legislation? Please elaborate
with reason(s).

https://form.gov.sg/#!/5f2c1858d6f2b00011ffb316

Question C3. Application for registration of transactions for IP
rights (optional)

5/8

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2020/9/14

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2020/9/14

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Although we don’t see any other speci c areas for our attention
at this time, it would be appreciated if you provide a certain
process in advance for remedies in timely manner not to burden
th
li
t h
i
bl
i di
d i thYes, we are supportive of the proposal to streamline the de nitionof “relevant parties” across the Trade Marks because the proposal
can reduce the burden on relevant parties.

Question C3. Application for registration of transactions for IP
rights (optional)
22.

SUBMITb) Do you have any re nement(s) to the proposed changes? If yes, please elaborate.

No, we do not have any re nement(s) to the proposed changes.

POWERED BY

D: IMPROVING USER EXPERIENCE ANDSERVICE WITH DIGITAL INITIATIVESreCAPTCHA で保護されていますQuestion D1. Use of Arti cial Intelligence technologies indecision making (optional)
23.

プライバシー - 利⽤規約a) Are the safeguard measures described in each example above suf cient? If not, what
are your concerns, and what other operational and/or legislative safeguard measureswould you deem necessary in the adoption of decision making by AI?

The safeguard measures described in Determining theRegistrability of Certain Trade Marks above look ok at this time.
Keeping certain several options on applicants for rescue byhuman examiners would be also appreciated.
Question D1. Use of Arti cial Intelligence technologies indecision making (optional)
24.

b) While IPOS will carry out due diligence and conduct rigorous testing before rollingout AI solutions, are there other speci c areas you think should be paid attention to? If
so, please elaborate on the reasons and also possible measures.

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Question
Question B1a) Do you agree with the adoption of the “partial refusal” mechanism for thenational Trade Mark regime? Please elaborate with reason(s).

Comment
Yes, we agree with the adoption of the “partial refusal” mechanism for the national
Trade Mark regime because we can have several options to pursue our partiallyrefused application depending on the nature of the objection(s). Meanwhile, please
note some of our member companies expressed concern that introducing partiallyrefusal may lead to an increasing number of registrations that are not used incommerce. Accordingly, we will pay attention that IPOS keeps controlling the balance
between cost efficiency and stability of trademark rights.

b) What is/are the key priority you consider in the course of Trade Markregistration? (e.g., speed, cost, specificity in relation to objectionable goods
and/or services, clarity in examination decisions)

We consider that speed, cost and clarity in examination decisions are the key priority
in the course of Trade Mark registration.

c) If you have a partially refused application, will you be more inclined to (i)proceed with an amendment as proposed by the Registrar; (ii) initiate anamendment form (and relevant fee) to remove the objectionable goods and/or
services; or (iii) wait for the stipulated deadlines to lapse and automaticallyproceed to the next processing stage? Please provide reason(s) for your option.
Question B2a) Do you generally vary the use of your Trade Marks (such as differences incolour, capitalisation, or positioning of elements) in the course of trade? If
so, how?
b) Are you supportive of the proposals to limit the maximum number and/or
type of marks that can be filed in a single application? Please elaborate
with reason(s).

We will be more inclined to wait for the stipulated deadlines to lapse and automaticallyproceed to the next processing stage because of the cost-saving.

Question C1a) Are you supportive of the proposed changes? Please elaborate with reason(s).

We are supportive of the proposed changes because we can reinstate a trademark
application which is treated as withdrawn due to irresistible forces.

b) Would you have any refinements to the proposed changes? If yes, pleaseelaborate.
Question C2a) Do you agree that the proposed corrections relating to priority details andname of applicant which result in a change in IP ownership should be
advertised? Please elaborate with reason(s).

No, we do not have any refinements to the proposed changes.

b) Are there any other proposed corrections that you think should be advertised?
Please elaborate with reason(s).

No, there are not any other proposed corrections.

No, we do not generally vary the use of our Trade Marks.

Yes, we are supportive of the proposals to limit the maximum number and/or
type of marks that can be filed in a single application because we think that capping
the number of marks in a series to 4 seems reasonable.

Yes, we agree that the proposed corrections relating to priority details and name of
applicant which result in a change in IP ownership should be advertised because theproposed changes can help promote greater transparency and certainty to the overallprosecution process.

c) Is 2 months a reasonable period for advertisement? If no, please propose aperiod and provide us with the rationale.
Question C3a) Are you supportive of the proposal to streamline the definition of “relevant
parties” across the Trade Marks, Registered Designs and Patents
legislation? Please elaborate with reason(s).
b) Do you have any refinement(s) to the proposed changes? If yes, pleaseelaborate.
Question D1a) Are the safeguard measures described in each example above sufficient?
If not, what are your concerns, and what other operational and/or legislative
safeguard measures would you deem necessary in the adoption of decision
making by AI?
b) While IPOS will carry out due diligence and conduct rigorous testing before
rolling out AI solutions, are there other specific areas you think that should be
paid attention to? If so, please elaborate on the reasons and also possible
measures.

2-months is a reasonable period for advertisement.
Yes, we are supportive of the proposal to streamline the definition of “relevant
parties” across the Trade Marks because the proposal can reduce the burden on
relevant parties.
No, we do not have any refinement(s) to the proposed changes.
The safeguard measures described in Determining the Registrability of Certain Trade
Marks above look ok at this time. Keeping certain several options on applicants forrescue by human examiners would be also appreciated.

Although we don’t see any other specific areas for our attention at this time, it would
be appreciated if you provide a certain process in advance for remedies in timely
manner not to burden the applicant when any coming problem is discovered in the
future as a risk management.