100 Secrecy, Access, National Security, and Foreign Filing

Clarify "expedited" FFL petition in 140, I.

MPEP 140, I. (Jan. 2018), at 100-35--36, is titled "Expedited Foreign Filing License." It references 37 CFR 5.12(b), which relates to a "petition for license." Would the Office please clarify what "Expedited" means here?


For most petitions, the Applicant can submit a separate petition under 1.182 to request expedited consideration of the substantive petition. However, as far as I know, there is only one type of petition for FFL, and it is given expedited handling as a matter of course. That is, there is no need to submit a separate petition under 1.182 to benefit from the "Expedited" handling mentioned in the MPEP. Right?


Since this is a special case, I would appreciate clarification in the MPEP. Perhaps the following:


- Remove all references to "expedited" in 140

- Change the title of 140, I to "Explicit Petition for Foreign Filing License"

- Amend 100-36, left column, second full paragraph, to begin "Generally ... business days from receipt of the [[expedited]]>express< petition..."


Thanks for considering this request!

(As always, all opinions are my own and not necessarily those of any other party.)



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Idea No. 249