We understand that the March 11, 2026 Director’s Memorandum on “Additional Discretionary Institution Considerations” reflects a recognition that the USPTO’s broad curtailment of access to Inter Partes Review (IPR) proceedings has harmed US manufacturers and related industries in many sectors. We welcome that recognition. However, we are concerned that the Memorandum does not address the underlying problem. It may instead exacerbate it. We offer these views in the hope of returning USPTO to the framework Congress established.