The Clearing House Association joined 16 other business associations in a letter to the USPTO to comment on a proposal implementing the transitional program for business-method patents. In addition to reiterating the importance of the transitional business-review program, the letter takes the following positions: (i) appropriate fees should be charged to ensure an effective review program, (ii) the burden should be on the patentee to show that the “technological invention” exception applies, (iii) there should be no restriction on requesting business-method-patent review of non-first-to-invent patents during the post-grant review period, (iv) the Office should further define “charged with infringement” and interpret “financial product or service” broadly in accordance with the purpose of the program, and (v) the Office should consider accepting petitions for business-method review before September 16.