2.20 Is it possible to submit informal comments on earlier search results? What is PCT Direct?
2.20.001On 1 November 2014, the EPO launched the PCT Direct service for international applications filed with the EPO as receiving Office. On 1 July 2015, this service was extended to international applications filed with all the other receiving Offices. Under PCT Direct, an applicant filing an international application with any receiving Office and claiming priority from an earlier application already searched by the EPO may, together with the request form, file a letter containing informal comments aimed at overcoming objections raised in the search opinion established by the EPO for the priority application32 (see point 3.2.026). The EPO as ISA will take informal comments submitted under PCT Direct into account when establishing the ISR and WO‑ISA.
32Generally, PCT Direct cannot be used where an international-type search was carried out on the earlier application. However, for the Netherlands and Belgium, the international-type search report established by the EPO is accompanied by a written opinion and PCT Direct can be used in those cases.